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petitioners. However, respondent subsequently determined that
petitioners’ claim was a timely request for a section 6330
hearing and released the levy.
By letter dated May 19, 2003, Appeals Officer Paula Stanton
advised petitioners that she had scheduled the requested hearing
for June 3, 2003, at 10 a.m. In that letter, Appeals Officer
Stanton warned petitioners that “I cannot consider issues
concerning the constitutionality of tax laws.”
Petitioners did not attend the hearing scheduled for June 3,
2003, and did not contact Appeals Officer Stanton to schedule a
new hearing. By letter dated June 3, 2003, and labeled “FINAL
OPPORTUNITY”, Appeals Officer Stanton warned petitioners that if
she did not hear from them on or before June 13, 2003, she would
issue a determination letter based on current information.
By letter dated June 30, 2003, Appeals Officer Stanton
rescheduled the hearing requested by petitioners for July 8,
2003. On July 8, 2003, the hearing was held. Petitioner Polly
Gatlos participated in the hearing. At the hearing, Mrs. Gatlos
challenged the constitutionality of the Internal Revenue Code and
refused to discuss collection alternatives. Petitioners raised
no relevant issue at the July 8 hearing.
On August 11, 2003, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (the notice of determination). In the notice of
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Last modified: May 25, 2011