- 6 - “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 issuesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011