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on July 2, 2003, but the hearing did not proceed when the Appeals
officer refused to permit petitioner to record the meeting.
Following the aborted meeting, in a July 3, 2003, letter to the
Appeals officer, petitioner listed issues that he wished to have
considered before any determination was issued. The enumerated
matters largely reprised the challenges submitted with
petitioner’s Form 12153, disputing, e.g., underlying liability,
proper assessment, receipt of valid notices of deficiency and
demand for payment, verification from the Secretary that all
applicable legal and procedural requirements had been met, and
right to record.
On October 7, 2003, respondent issued to petitioner the
aforementioned Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330, sustaining the proposed
lien action.
Petitioner’s petition disputing the notice of determination,
having been timely mailed, was filed with the Court on
November 12, 2003, and reflected an address in Las Vegas, Nevada.
In the petition and in an accompanying document filed as a motion
to dismiss for lack of jurisdiction, petitioner relied
principally on the claim that he was denied a proper hearing
under section 6330 due to the inability to record.2
2 Petitioner’s motion to dismiss for lack of jurisdiction
was denied by order of this Court on Jan. 22, 2004.
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Last modified: May 25, 2011