Kenneth P. Krueger - Page 4

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               Petitioner and his wife did not file a petition with the               
          Court to redetermine the deficiency.  Instead, petitioner mailed            
          a letter dated July 25, 2002, to the contact person named in the            
          notice of deficiency with copies to the Secretary of the                    
          Treasury, the Commissioner of Internal Revenue, Senator Baucus,             
          Chairman of the Senate Finance Committee, Senator Conrad,                   
          Chairman of the Tax and IRS Oversight Sub-Committee, and                    
          Congressman Thomas, Chairman of the House Ways and Means                    
          Committee, stating that he would not file a petition with the Tax           
          Court until it was established that respondent had the legal                
          authority to send the notice of deficiency in the first place.              
               Respondent assessed the tax, penalty, and interest on                  
          November 18, 2002.  On March 4, 2003, respondent mailed to                  
          petitioner a Final Notice--Notice of Intent to Levy and Notice of           
          Your Right to a Hearing.  The final notice was not addressed to             
          petitioner’s wife, Sandra C. Krueger.  On April 2, 2003,                    
          petitioner timely filed a Form 12153, Request for a Collection              
          Due Process Hearing.  Petitioner’s wife did not sign the Form               
          12153 and was not involved in the subsequent section 6330 hearing           
          or in the proceedings herein.                                               
               On April 8, 2004, respondent sent a letter to petitioner               
          advising him that a face-to-face conference would not be allowed            
          if petitioner continued making frivolous and groundless                     
          arguments.  The letter further stated:  “If you wish to have a              






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