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The taxpayer stated he did not receive the letter of
notice and demand. The certified transcript shows it
was issued to him on 01/08/2001, at which time his last
known address was 4104 E. Harmon as indicated by com-
puter transcripts. The taxpayer also stated his ad-
dress at that time was 4104 E. Harmon. This was the
same address as it was when he received and responded
to both the statutory notice of deficiency dated
08/04/2000, and the Letter 1058 dated 07/30/2001.
Today he still lives at 4104 E. Harmon. Therefore, it
is presumed he did receive the letter of notice and
demand.
The taxpayer raised no non-frivolous arguments.
I raised the issue of collection alternatives with the
taxpayer. He was not interested. He said he would pay
the tax due if it could be proven to him that it was
owed, but since he does not believe wages are income,
this discussion was fruitless. In addition, since the
taxpayer has not filed any returns since 1997, he is
not in filing compliance, and therefore, is not now
eligible for an offer in compromise or an installment
agreement.
Balancing the Need for Efficient Collection with Tax-
payer Concerns
The requirements of all applicable laws and administra-
tive procedures have been met. The taxpayer received
all his required notices. The assessment is valid.
Given the taxpayer’s continued lack of compliance with
the tax laws, a levy or levies on his property or
rights to property would not be considered more intru-
sive than necessary when balancing the government’s
need for efficient collection with his concerns.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994).
In petitioner’s response to respondent’s motion (peti-
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