Randy S. Quigley - Page 6

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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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