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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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