- 5 - Petitioner and the Appeals officer held two telephone conversations on July 2, 2001, and October 23, 2001. After the telephone conversations petitioner submitted a 50-page document that contained tax-protester arguments. A face-to-face meeting was held on December 19, 2001, at which petitioner told the Appeals officer that he believed he had been coerced into signing the Form 4549-CG. Petitioner was allowed to review the Appeals officer’s administrative file and was provided copies of documents he requested. On January 14, 2002, petitioner submitted a 37-page written document to the Appeals officer. The document contained tax- protester arguments. In the December 12, 2002, Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for 1996 and 1997, the Appeals officer found there to be “no credible evidence that any Internal Revenue Service employee procured the taxpayer’s waiver of the restrictions on assessment through duress, coercion, fraud, or misrepresentation.” The Appeals officer also determined that collection may proceed for 1996 and 1997. In making the determination, the Appeals officer relied on transcripts of petitioner’s account to verify the assessments. On January 10, 2003, petitioner filed a petition for judicial review of respondent’s determination with the Court.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011