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“Tax Law: Federal Tax Administration & Procedure: Tax
Liabilities & Credits: Levy & Distraint (IRC secs.
6331-6344, 7429) With respect to a hearing concerning
the proposed levy of a taxpayer’s property, the tax-
payer is to have a meaningful hearing, followed by
judicial review. IRC Sec 6330(d)(1)(B).”. A hearing
where I can present evidence, ask questions and view
the verification documents called for in the law.
[Reproduced literally.]
In response to petitioner’s February 4, 2004 letter and a
prior telephone call that petitioner made on a date not disclosed
by the record, the Appeals officer sent a letter to petitioner on
February 6, 2004 (Appeals officer’s February 6, 2004 letter),
which stated in pertinent part:
I’ve received your call and letter requesting a face-
to-face Hearing. The items that you mention in your
CDP request are items that:
• Courts have determined are frivolous or
groundless, or
• Appeals does not consider. These are moral,
religious, political, constitutional, consci-
entious, or similar grounds.
Examples of arguments that are considered frivolous or
groundless are provided in “The Truth About Frivolous
Tax Arguments” on the IRS Internet website at
http://www.irs.gov/pub/irs-utl/friv tax.pdf. It is not
a complete list of frivolous and groundless arguments.
I previously provided a list of cases in the Collection
Due Process forum in which the arguments you are rais-
ing were considered frivolous and irrelevant.
Appeals does not provide a face-to-face conference if
the only items you wish to discuss are those mentioned
above. You may, however, have a telephone conference
or discuss with us by correspondence any relevant
challenges to the filing of the notice of federal tax
lien or the proposed levy.
If you are still interested in receiving a face-to-face
conference, you must be prepared to discuss issues
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Last modified: May 25, 2011