- 8 -
hearing and then abruptly terminated the hearing before
petitioner could present his arguments. Petitioner also contends
that during their January 31, 2002, telephone call, Mrs. Strong
told petitioner that the only matter she would discuss with
petitioner at the hearing would be “payment” of his income tax
liabilities.
After listening to Mrs. Strong’s testimony at trial and
reviewing petitioner’s tape recording of the hearing, we disagree
with petitioner’s characterization of the hearing. Throughout
the hearing, Mrs. Strong made several patient attempts to keep
petitioner focused and invited petitioner to raise issues
relevant to his income tax liabilities. When petitioner
eventually digressed into frivolous5 challenges to the underlying
tax liabilities, Mrs. Strong concluded the hearing. Petitioner
had a fair opportunity to fully address all relevant issues
pursuant to section 6330(c)(2) and failed to take advantage of
it.
Petitioner has failed to demonstrate that the proposed levy
action is inappropriate, another collection alternative is more
appropriate, or some other relevant issue adversely affects
respondent’s proposed collection activity. We therefore conclude
that respondent’s determination to proceed by levy with the
collection of petitioner’s 1997, 1998, and 1999 income tax
5See supra note 4.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011