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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
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