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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.
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