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Background
At the time of the filing of the petition, petitioner
resided in San Jose, California.
On his 1999 tax return, petitioner reported zero income and
requested a full refund of all taxes withheld. Petitioner
attached to his tax return two pages of tax-protester boilerplate
which asserted that no section of the Internal Revenue Code made
him liable for income taxes. Petitioner’s Form W-2, Wage and Tax
Statement, reported that petitioner received wages of $163,908.87
from Web TV Networks, Inc., in 1999.
On July 12, 2002, respondent sent petitioner a notice of
deficiency for 1999 to 560 Hobie Lane, San Jose, California
95127. Petitioner resided at this address from July 12, 2002 to
January 30, 2004. Petitioner failed to petition the Court to
review the notice of deficiency.
On April 7, 2003, respondent issued to petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing. On April 14, 2003, petitioner mailed respondent a Form
12153, Request for a CDP Hearing, and attached a page of tax-
protester arguments, which disputed the validity of and requested
that the Appeals officer have at the hearing copies of documents
pertaining to, among other things, the underlying tax liability,
the assessment, the notice and demand for payment, and the
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Last modified: May 25, 2011