Raymond Gori - Page 3

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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               
                                                             (continued...)           





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