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Service Form CP90. In response, on or about January 2,
2003, petitioner filed Form 12153, Request for a Collection
Due Process Hearing. In the space on the form which asks
“why you don’t agree” with the notice of levy/seizure,
petitioner stated as follows: “Due to the fact that I
responded to every ‘notice’ with questions I needed to be
answered in order to proceed--I never received a response
to my questions.”
A representative of the Internal Revenue Service Office
of Appeals contacted petitioner by letters dated June 9,
2003, and June 30, 2003, and spoke to petitioner by
telephone on June 30, 2003, and August 18, 2003.
Respondent’s motion for summary judgment states that the
“CDP hearing” took place during the telephone conversation
on June 30, 2003, and, during that conversation, “petitioner
inquired as to the legal definition of income.” In
response, the Appeals officer sent to petitioner the letter
dated June 30, 2003, which enclosed a document entitled,
“The Truth about Frivolous Tax Arguments” to provide “an
explanation for the reasons to file a tax return”. The
June 30, 2003, letter also states that petitioner’s account
balance for 1996 is $5,324.42 as of May 12, 2003.
The letter also refers to a letter from petitioner dated
June 24, 2003, which is not included in the record.
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Last modified: May 25, 2011