- 4 - issue. Petitioner questioned Appeals Officer Driver’s authority to conduct a section 6330 hearing and wanted to discuss his underlying liabilities for 1994, 1995, and 1996. On September 26, 2003, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 to petitioner regarding his 1994, 1995, and 1996 tax years. In the notice of determination, respondent determined that the proposed collection actions were appropriate and to proceed with collection. On October 24, 2003, petitioner petitioned the Court. On December 11, 2003, petitioner filed a motion for judgment on the pleadings. Petitioner asked that the answer be stricken from the record. Petitioner characterized the primary issue in his case as whether he was a “taxpayer” and stated that he had challenged this issue. The motion for judgment on the pleadings also contained other frivolous and groundless statements, contentions, and arguments. On December 16, 2003, the Court denied petitioner’s motion for judgment on the pleadings. On January 6, 2004, petitioner filed a status report containing frivolous and groundless statements, contentions, and arguments. By notice dated June 30, 2004, the Court set this case for trial at the Court’s Dallas, Texas, session beginning December 6,Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011