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On February 4, 2004, respondent sent petitioner a final
notice--notice of intent to levy and notice of your right to a
hearing regarding petitioner’s 1998, 1999, and 2000 tax years
(notice of levy).
On or about March 7, 2004, respondent received a Form 12153,
Request for a Collection Due Process Hearing, regarding
petitioner’s 1998, 1999, and 2000 tax years (hearing request).
The hearing request was postmarked February 27, 2004, and
respondent treated it as received timely. In the hearing
request, petitioner checked the box for notice of levy/seizure
and in the space to explain why he did not agree he wrote: “Not
Liable.”
On June 15, 2004, Settlement Officer J. Feist, from
respondent’s Tampa Appeals Office, mailed petitioner a letter
that scheduled a section 6330 hearing for June 24, 2004.
Settlement Officer Feist gave petitioner transcripts of his
account for the years in issue and offered petitioner an
opportunity for a face-to-face section 6330 hearing. In light of
the fact that petitioner raised frivolous arguments in the past,
however, Settlement Officer Feist instructed petitioner to write
by June 22, 2004, specific relevant issues before he would grant
a face-to-face section 6330 hearing. At that time, Settlement
Officer Feist also provided petitioner with a document entitled
“The Truth About Frivolous Tax Arguments” and a link to an IRS
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Last modified: May 25, 2011