- 6 - 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. HePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011