James G. Gilligan - Page 4

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          Immunities (at 4:2:1), and the lesser UCC/Uniform Commercial Code           
          (at �1.207) ‘with reservation of all our rights’, for the                   
          Record!”.                                                                   
               On December 17, 2001, the IRS sent petitioner a “Final                 
          notice--notice of intent to levy and notice of your right to a              
          hearing” for 1992, 1993, 1994, and 1996.  On January 8, 2002,               
          petitioner submitted a Form 12153, Request for a Collection Due             
          Process Hearing, with an 11-page attachment asserting frivolous             
          and meritless arguments.                                                    
               On July 10, 2002, Appeals Officer Eric Johansen conducted a            
          section 6330 hearing (hearing) in person with petitioner.                   
          Petitioner requested that the hearing be tape recorded; however,            
          the Appeals officer advised petitioner that the hearing could not           
          be tape recorded.  At the hearing, petitioner did not raise any             
          spousal defenses.  He did not propose any collection                        
          alternatives.  Petitioner refused to sign a Form 433-A,                     
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals, despite his contentions that he was                   
          unemployed and had no money to pay the tax liability.                       
               On August 15, 2002, the IRS issued petitioner a Notice of              
          Determination Concerning Collection Action(s) under Section 6320            
          and/or 6330 (notice of determination) to proceed with collection.           
               On September 13, 2003, petitioner filed a petition with the            








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