- 5 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011