Deborah Carman Goodin - Page 5

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          notice of determination concerning collection action(s) under               
          section 6320 and/or 6330 (notice of determination).  A document             
          that was attached to and incorporated in that notice of determi-            
          nation stated in pertinent part:                                            
                               SUMMARY AND BACKGROUND                                 
               The taxpayer submitted a timely request for a Collec-                  
               tion Due Process Hearing in response to the notice of                  
               lien filing.                                                           
               The taxpayer’s request for a Due Process Hearing stated                
               “Mathmaticaly incorrect” Since she received a statutory                
               notice of deficiency, she was told that she could not                  
               dispute the liability under collection due process, and                
               the audit reconsideration process was explained to her.                
               Publication 3598 was also sent to her.  In her phone                   
               conference, the taxpayer stated that she would pay the                 
               tax if we could show her that she was liable for the                   
               tax.  Appeals faxed her code, regulations and court                    
               cases, but her response by letter dated 3/10/2004                      
               states “I have a copy of the IRC and the part of the                   
               Index, in the front under the subject of ‘Liability for                
               Tax’ doesn’t even mention Subtitles A through C income                 
               taxes.  I have been looking for the laws and IRC Stat-                 
               utes and Regulations and they show I am not liable, but                
               absolutely none of them show that I am.  I am not                      
               refusing to pay as you are requesting if you would                     
               please show me that the law says I have ‘gross income’                 
               form a taxable ‘situs’ under 26 CFR section 1.861-8(f)                 
               that is legally considered as ‘taxable’ income.”  These                
               arguments are frivolous and need not be addressed                      
               further, as the information she requested has been                     
               provided to her.  The taxpayer has not provided any                    
               documentation or collection alternatives.                              
                    Applicable Law and Administrative Procedures                      
               With the best information available, the requirements                  
               of various applicable law or administrative procedures                 
               have been met.                                                         
               IRC � 6321 creates a lien on the taxpayer’s property if                
               the taxpayer neglects or refuses to pay the tax after                  
               the tax is assessed and after notice and demand for                    

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Last modified: May 25, 2011