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“contracts” that require petitioner to pay taxes; and (3) the
list of taxable “objects” owned by petitioner. Petitioner also
demanded that he be allowed to question respondent’s revenue
agents.
By letters dated June 19, 21, and 26, 2001, respondent
attempted to schedule a hearing with petitioner. On June 28,
2001, respondent sent petitioner transcripts of accounts which
delineated all assessments for each of the years in issue. By
letter dated June 28, 2001, petitioner declined to participate in
a hearing, stating that “No hearing can possibly take place * * *
[until] the government * * * [produces]” the documents
establishing that he is subject to tax. The June 28, 2001,
letter also states that he is not a “United States individual”
subject to tax and only certain Federal employees are subject to
tax. Petitioner did not propose collection alternatives, raise
spousal defenses, or allege that he did not receive statutory
notices of deficiency relating to the years in issue.
On July 31, 2001, respondent issued petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330, in which respondent determined that the Notice of
Federal Tax Lien should not be withdrawn, all legal and
procedural requirements for collection had been met, and the
filing of the lien was reasonable and not intrusive under the
circumstances.
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Last modified: May 25, 2011