-5-
(2) a copy of Pierson v. Commissioner, 115 T.C. 576 (2000);
(3) respondent’s publication entitled “Why I Have to Pay
Taxes”;
(4) respondent’s publication entitled “The Truth About
Frivolous Tax Arguments”;
(5) a list of Internal Revenue Code sections; and
(6) a copy of a news release from the Justice Department
asking the court to stop promoters of abusive tax schemes.
Petitioners submitted a joint affidavit that contained a record
of their contacts with respondent and made various contentions.2
At the hearing, petitioners were provided an opportunity to but
did not submit a viable collection alternative, such as an
installment agreement or an offer in compromise.
On April 8, 2003, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330, determining that the proposed levy action was
appropriate. Before issuing the notice of determination, Appeals
Officer Freitag reviewed respondent’s records for petitioners’
1997 tax year, including the Form 4340.
Petitioners timely filed in this Court a petition for lien
or levy action, contending, inter alia, that (1) the Appeals
Office did not consider petitioners’ allegations of
2The 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.”
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011