-3-
and a section 6662 accuracy-related penalty of $62,544.20.
Petitioners received the notice but did not file a petition with
this Court for a redetermination of the deficiency pursuant to
section 6213. Consequently, respondent issued a Final Notice--
Notice of Intent to Levy and Notice of Your Right to a Hearing,
informing petitioners of respondent’s intent to levy and of
petitioners’ right to a hearing before respondent’s Appeals
Office pursuant to section 6330. In response, petitioners timely
filed a Form 12153, Request for a Collection Due Process Hearing.
In a letter dated April 25, 2003, Appeals Officer Jerry L.
Johnson notified petitioners that (1) the section 6330 hearing
had been scheduled for May 9, 2003, (2) petitioners would not be
permitted to record the hearing, and (3) petitioners could choose
a hearing by correspondence in lieu of a personal appearance
before Appeals Officer Johnson. In response, petitioners
requested a hearing by correspondence and submitted a joint
affidavit containing a record of petitioners’ contacts with
respondent and making various contentions.1
1The foregoing contentions include the following: “To the
best of my knowledge, I am not, nor have I ever been, statutorily
liable or made liable for any tax pursuant to 26 USC.” In a
letter dated May 10, 2003, petitioners described the contentions
contained in their affidavit as follows:
You will find no frivolous arguments in the packet we
sent you. Some of the issues we raised are as follows:
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011