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of deficiency. On October 9, 2000, respondent assessed the
deficiency, additions to tax, and interest. On October 9 and
November 13, 2000, respondent sent petitioner notices of balance
due with respect to the 1997 liability. Petitioner responded to
the November 13, 2000, notice of balance due with a letter
containing frivolous and groundless arguments challenging the
deficiency and the additions to tax.
On February 19, 2001, respondent issued a notice of intent
to levy to petitioner. On February 26, 2001, petitioner replied
in a letter containing frivolous and groundless challenges to the
1997 deficiency and additions to tax. On February 26, 2002,
respondent filed a notice of Federal tax lien with the Clerk of
Superior Court, Haralson County, Georgia. On March 1, 2002,
respondent issued to petitioner a Notice of Federal Tax Lien
Filing and Your Right to a Hearing Under IRC 6320 with respect to
the 1997 liability. On March 4, 2002, respondent sent to
petitioner a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing. On March 28, 2002, petitioner filed
Form 12153, Request for a Collection Due Process Hearing, and
attached five pages of frivolous and groundless arguments
challenging the 1997 liability and the validity of the various
notices respondent had sent him.
Petitioner exchanged several letters with the Internal
Revenue Service (IRS) Appeals officer assigned to his case to
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Last modified: May 25, 2011