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face-to-face conference, please write me within 15 days from the
date of this letter and describe the legitimate issues you will
discuss.” In the same letter respondent proposed that a
telephone conference be held on April 28, 2004. Petitioner
acquiesced to the telephone conference and subsequently
rescheduled it for May 11, 2004.
During the May 11, 2004, telephone conference, the
settlement officer advised petitioner of the appeals process and
his rights as a taxpayer. Petitioner raised only frivolous
arguments consistent with those found in the attachments appended
to the 2000 tax return and incorporated in prior correspondence.
During the morning of the conference, petitioner faxed to
respondent’s settlement officer a copy of an offer in compromise
he intended to file. Petitioner did not pay the $150 processing
fee at the time of filing, and it was not processed.
Petitioner’s offer was based on “Doubt as to Liability” and was
accompanied by an attachment reciting that wages are not income
and that no section of the Internal Revenue Code establishes an
income tax liability.
In the June 4, 2004, Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 for 2000
(notice of determination) sent to petitioner, the Appeals officer
determined:
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Last modified: May 25, 2011