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the specific documents as identified above, or
“verification from the Secretary.” If the appeals
officer cannot produce neither document, than no Due
Process Hearing should be scheduled until he has those
documents in hand. If the appeals officer recommends
“enforcement of collection action including levy,”
without having produced these specific documents, then
it will be obvious that the appeals officer is simply
attempting to thwart and circumvent the Code Section
6330 in order to enable the IRS to continue its
practice of making the illegal seizures uncovered by
the Senate Finance Committee * * * which THE “DUE
PROCESS HEARING” was designed to eliminate.
Summarizing: We requested a “Due Process Hearing”
as outlined in Form 12153. We are “challenging the
appropriateness of (the) collection action” as
specified in 6330(c)(2)(A)(ii) since the IRS denied all
of our requests for the initial “examinations” and
“interviews” as provided for in Publications 1 & 5. In
addition, no lien for taxes pursuant to Code Sections
6321 and 6322 is possible because no valid, underlying
assessment was ever made. In addition, we never
received the statutory “notice and demand” for payment
of the taxes at issue as required by Code Sections
6203, 6321, and 6331. If the appeals officer is going
to claim that a particular document sent to me by the
IRS was a “Notice and Demand” for payment, then I am
requesting that he also provide me with a T.D. or
Treas. Reg. which identifies that specific document as
being the official, statutory “Notice and Demand” for
payment.
In addition, we are “challenging the existence of
the underlying tax liability” as we are authorized to
do in Code Section 6330(c)(2)(B). In addition, we did
not receive a (valid) notice of deficiency in
connection with any of the years at issue. We are also
requesting that the appeals officer have at the “Due
Process Hearing” a copy of the “Summary Record of
Assessment” (Form 22 C) together with the “pertinent
parts of the assessment which set forth the name of the
taxpayer, the date of the assessment, the character of
the liability assessed, the taxable period, and the
amount assessed” as provided for in Treas. Reg.
301.6203-1.
Also you are reminded that the Section 6330(c)(1)
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