- 4 - On December 14, 2001, in response to respondent’s notice of Federal tax lien filing, petitioners filed with respondent a request for a hearing, which was held on October 17, 2002, with respondent’s Appeals Office in Portland, Oregon. At the Appeals Office hearing, petitioners argued that they were not taxable on their income. Petitioners did not claim any error had occurred in respondent’s collection procedures, nor did petitioners raise any collection alternatives. On November 19, 2002, respondent mailed to petitioners a notice of determination in which respondent determined that respondent’s tax lien constituted a valid and appropriate collection activity against petitioners. On December 11, 2002, petitioners filed their petition herein in which petitioners claim only that they are not subject to the income tax. Petitioners make no claim of irregularity in respondent’s collection procedures. Quoting from petitioners’ pretrial memorandum, petitioners argue that –- A careful examination of 26 C.F.R. sec. 1.861-8, (as well as over 80 years of predecessor statutes and regulations) shows that taxable sources of income are limited to the following types of commerce: (1) Certain foreign income of U.S. citizens (26 C.F.R. sec. 1.861-8(f)(1)(i)); (2) The domestic income of foreigners (26 C.F.R. sec. 1.861-8(f)(1)(iv)); (3) Certain income related to federal possessions (26 C.F.R. sec. 1.861-8(f)(1)(vi)(E)).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011