- 2 - Petitioner seeks review under section 6330(d) of respondent’s determination sustaining a proposed levy for the collection of his 1998 tax liability in the amount of $18,868.98.2 The issue is whether petitioner’s case should be remanded to Appeals for a face-to-face collection due process hearing. At the time he filed the petition, petitioner was a resident of Norton, Ohio. Background Petitioner filed a Form 1040, U.S. Individual Income Tax Return, for the taxable year 1998 reporting a tax liability due. Petitioner did not pay the amount he reported due. After receiving respondent’s Notice of Intent to Levy and Notice of Your Right to a Hearing, petitioner filed a Form 12153, Request for a Collection Due Process Hearing. In his Form 12153, petitioner asserted he was not liable for the tax due and made arguments that are considered frivolous and irrelevant by the Internal Revenue Service and this Court.3 2 This is the amount of the liability as of Oct. 23, 2003. The record is not clear as to how this amount breaks down into the original amount due reported on petitioner’s 1998 return and any additions to tax that have since accrued. 3 The record is not clear as to the exact arguments that were made by petitioner in his collection due process hearing request. It appears from an attachment to his petition that petitioner asserts arguments challenging the constitutional validity of his tax liability and the authority of the Internal Revenue Service. These arguments have universally been rejected as frivolous and warrant no further comment. “We perceive no (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011