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3. None of the issues raised by petitioner were
meritorious.
4. No spousal defenses applied because petitioner filed as
“single”.
5. The proposed levy action balanced the need for efficient
collection of taxes with the legitimate concern of the taxpayer
that the collection action be no more intrusive than necessary
and was appropriate under the circumstances.
Petitioner mailed a letter dated March 3, 2002, to this
Court that this Court treated as a timely, but imperfect,
petition appealing respondent’s determination for 1997, 1998, and
1999. This Court then mailed petitioner an order requiring him
to file a proper amended petition. On April 26, 2002, petitioner
filed the amended petition.
In his original and amended petitions, petitioner alleged
that he was denied a “fair and impartial hearing” under section
6330. Specifically, petitioner claimed that (1) he was denied
the opportunity to “raise any relevant issue concerning the
appropriateness of collection”, in violation of section
6330(c)(2)(A)(ii), and (2) he was denied the opportunity to
properly challenge the existence or amount of the underlying tax
liability, in violation of section 6330(c)(2)(B). Additionally,
in his amended petition, petitioner disputed the existence of his
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