- 6 - discuss collection alternatives unless her liability was proven to her. Petitioner’s petition disputing the notice of determination was filed with the Court on September 9, 2003, and reflected an address in Window Rock, Arizona. Petitioner’s complaints with respect to the administrative proceedings include the following: No legitimate hearing under section 6330 ever took place; petitioner was not permitted to record a hearing; petitioner was denied the opportunity to raise issues she deemed “relevant” (e.g., the “existence” of the underlying tax liability); and requested documentation was not produced (e.g., record of the assessments, statutory notice and demand for payment, any “valid notice of deficiency”, various delegations of authority, and verification from the Secretary that all applicable requirements were met). Petitioner prays that this Court declare invalid the August 14, 2003, determination; order the IRS to hold the statutorily mandated “Collection Due Process Hearing”; order the IRS to have at the hearing all documents requested by petitioner; and order the Government to reimburse petitioner for all costs incurred in submitting the instant petition.2 After the pleadings were closed in this case, respondent filed the subject motion for summary judgment and to impose a 2 The Court notes that to the extent that the petition seeks reasonable administrative and/or litigation costs pursuant to sec. 7430, any such claim is premature and will not be further addressed. See Rule 231.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011