Gregory L. Shireman - Page 5

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               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.               








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