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determined that petitioner is liable for additions to tax of
$7,588 for failure to timely file under section 6651(a)(1) and
$1,566 for failure to pay estimated tax under section 6654.
Petitioner wrote to respondent on June 18, 2003, and
acknowledged that he had received the notice of deficiency. In
the letter, petitioner questioned whether the notice of
deficiency was valid and whether respondent’s representative had
authority to send the notice of deficiency.
Petitioner did not file a petition in the Tax Court for
2000. Respondent assessed tax and additions to tax for
petitioner’s 2000 tax year on October 20, 2003.
5. Respondent’s Notice of Intent To Levy and Petitioner’s
Request for a Hearing
On December 13, 2003, respondent issued to petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing
relating to his 2000 tax liability. Petitioner requested a
hearing. In his request, petitioner contended that: (a) No
statute requires him to pay income tax; (b) no law authorizes
respondent to claim that he owes any income tax for 2000; (c) the
“IRS Decoding Manual” establishes that he owes no income tax for
2000; and (d) the Secretary has not authorized any action for the
collection of taxes and penalties as required by section 7401.
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Last modified: May 25, 2011