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sent to petitioner a notice of balance due relating to her tax
liability for 1996.
B. Notice of Intent To Levy and Collection Due Process Hearing
On December 21, 2000, respondent issued to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing relating to petitioner’s 1996 tax year. Petitioner
requested a hearing, which was held by respondent’s Appeals
officer, Melvin Iwane (Iwane), on April 12, 2001. At the
hearing, Iwane gave petitioner an opportunity to challenge her
underlying tax liability for 1996, but petitioner did not do so.
Petitioner asked Iwane to show her the statute that makes her
liable for tax and contended that the person or persons who sent
notices to her did not have authority to do so. Iwane did not
give to petitioner delegation orders showing that those notices
were issued by persons with authority to do so, copies of the law
which makes her liable for income taxes, or written verification
that the requirements of applicable law and administrative
procedure have been met. At the hearing with Iwane, petitioner
contended that no valid statutory notice of deficiency had been
sent to her and that respondent erred by not using Form 17 for a
statutory notice and demand. Iwane did not consider those
arguments because he concluded that they were frivolous.
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Last modified: May 25, 2011