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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,
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Last modified: May 25, 2011