- 8 -
An attachment to the notice of determination stated in
pertinent part:
Legal and Procedural Requirements
* * * * * * *
This Appeals Officer has had no prior involvement with
respect to these liabilities; all relevant legal and
procedural requirements were reviewed and verified as
being met also no spousal issues are applicable.
Validity of the Assessment
The assessments for all tax years and liabilities
therein are valid. Various transcripts were reviewed
and all assessments were appropriate. For the Income
Tax liability for tax year 1999 you were issued a
Notice of Deficiency on 7/29/2003 [sic]. You did not
petition the Tax Court for re-determination and the tax
was appropriately assessed by default procedures.
Based on the above[,] Section 6330(c)(2)(B) precludes
any challenge to the underlying liability, at the
hearing, for any period, if the person received a
statutory notice of deficiency or otherwise had an
opportunity to dispute the liabilities. For the income
tax liability you received the Notice of Deficiency.
* * * * * * *
Challenges to the Appropriateness of the Collection
Actions
Your only challenge to the appropriateness of the
collection actions is documented in your request for
the hearing and other documents received by the Ser-
vice. Those challenges are submitted below in perti-
nent part:
• Quotations form [sic] Senator Roth’s
book “The Power to Destroy” specifically
page 73;
• Disputes the validity of the “Final
Notice of Intent to Levy and Notice of
your Right to a Hearing” pursuant to IRC
6330, because no one signed it.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011