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petitioner submitted to respondent a Form 12153, Request for
Collection Due Process Hearing, challenging the validity of the
assessments for the years in issue. With regard to the taxable
year 1983, petitioner asserted that his liability for that year
was either paid in full or discharged in bankruptcy.
On May 1, 2003, petitioner appeared at respondent's Appeals
Office for an administrative hearing under section 6330. The
administrative hearing was aborted when petitioner was informed
that he would not be permitted to make an audio recording of the
hearing.
On May 6, 2003, the Appeals Office issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 which stated that the Appeals Office
determined that the proposed levy action was appropriate. The
notice of determination stated that the Appeals Office rejected
petitioner's claim that his tax liability for 1983 was discharged
in bankruptcy on the ground that such taxes were not subject to
discharge because petitioner failed to file a valid tax return
for 1983. The notice of determination further stated that
petitioner was provided with transcripts of account for the years
1983 and 1993 to 1995, that petitioner's remaining arguments were
frivolous, and that petitioner was not eligible to offer an
alternative collection method because he was not current in
filing his tax returns for later years.
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