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Penalties were not assessed since the taxpayer was fully
cooperative and wants to eventually file an Offer and
Compromise with Collection.
On July 24, 2000, respondent assessed tax liabilities,
including additions to tax and interest, against petitioner in
the amounts of $861 and $6,995 for 1996 and 1997, respectively.
Respondent sent petitioner a Final Notice--Notice of Intent to
Levy and Notice of Your Right to a Hearing (Final Notice) for
1996 and 1997, on November 10, 2000.
On December 8, 2000, respondent received from petitioner a
Form 12153, Request for Collection Due Process Hearing. In the
Form 12153 petitioner argued that “The numbers are all wrong, you
owe me a refund.” Petitioner attached to the Form 12153 a 3-page
statement that contained tax-protester arguments.
In October 2001, petitioner mailed a document entitled
“Notice of Revocation of Signatures and Affidavit in Support
Thereof” to Treasury Secretary Paul O’Neill, IRS Commissioner
Charles Rossotti, and Attorney General John Ashcroft. Petitioner
also mailed a letter entitled “Request for Status Determination”
to IRS Commissioner Charles Rossotti. Both of these documents
contained tax-protester arguments.
Prior to the section 6330 hearing (hearing), respondent sent
petitioner transcripts of account for 1996 and 1997 at
petitioner’s request.
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Last modified: May 25, 2011