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demand letters were issued by regular mail to the
taxpayer’s last known address as required under I.R.C.
6303, demonstrated by the forms 4340 in the administra-
tive file;
There was an assessed liability and a levy source
determined by the Revenue Officer at the time the
notice of intent to levy was issued to TP;
The notices required under I.R.C. 6330 were pro-
vided to TP on the dates shown above in relation to the
levy notice, L-1058;
* * * * * * *
Both certified transcripts, and non-literal transcripts
were requested and reviewed by this A.O. Copies of the
certified transcripts were provided to the taxpayer.
Review of those documents and others in the administra-
tive file show that (a) TP did not receive a notice of
deficiency with respect to the underlying liability–-it
pertains to a math error correction of the withholding
taxes he had claimed so one was not required; * * *
(c) the tax to which the intent to levy related was
assessed properly since no notice of deficiency was
required; * * * (e) Notice and Demand was issued to
TP’s last known address; (f) TP failed to pay the
amount requested; and, (g) the collection officer
followed proper procedures in determinating a levy
should be initiated.
* * * * * * *
Issues Raised by the Taxpayer
In his appeal request, TP provided a lengthy document
in which his interpretation of the law, his rights, and
why he did not owe the tax was offered. The arguments
are without substance and include many theories of the
type described by the Courts as “frivolous.” * * *
At the hearing, TP was provided many documents, includ-
ing court cases from the Tax Court and Ninth Circuit
Court of Appeals, sections of the I.R.C., statements
from self proclaimed tax protestors, and others in
which it was demonstrated that TP could be sanctioned
for even carrying on with his arguments. He was then
offered the opportunity to suggest payment alternatives
and to argue the appropriateness of the collection
action. He had nothing of substance to contribute. He
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Last modified: May 25, 2011