John J. Delgado - Page 6

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          petitioner’s request for a face-to-face and recorded section 6330           
          hearing, but he suggested that petitioner could and should submit           
          collection alternatives to him at the scheduled hearing time.               
               On July 8, 2004, Settlement Officer Feist called petitioner            
          to conduct a telephonic section 6330 hearing.  During the section           
          6330 hearing, Settlement Officer Feist offered petitioner the               
          opportunity to raise relevant issues.  Petitioner raised                    
          additional frivolous arguments, including one answered on page 36           
          of “The Truth About Frivolous Tax Arguments.”  Petitioner chose             
          not to offer a collection alternative.  Petitioner insisted on a            
          face-to-face and recorded section 6330 hearing.                             
               On July 12, 2004, respondent issued a Notice of                        
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 to petitioner regarding his 1998, 1999, and 2000 tax            
          years (notice of determination).  In the notice of determination,           
          respondent determined that the filing of the notice of levy                 
          should not be withdrawn.                                                    
               As of July 15, 2004, petitioner’s unpaid liabilities for               
          1998, 1999, and 2000 were $2,041.57, $22,257.87, and $51,510.14,            
               In the petition, petitioner’s only assignment of error was             
          that respondent did not allow or provide him a face-to-face                 
          section 6330 hearing pursuant to the regulations under section              

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