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Collection Alternatives Considered
You have not suggested any viable alternatives. On
January 5, 2004 (note: typo error on letter has 2003)
you were sent a contact letter informing you that the
hearing was being conducted by correspondence and
telephone, you were advised that your irrelevant,
frivolous, meritless arguments were not acceptable and
that the hearing was being limited to discussions of
alternatives to the proposed levy. You were further
notified that you were not in compliance with the
filing of your 2000, 2001, and 2002 tax returns. You
were directed to forward completed returns for these
years along with financial statements.
In response you wrote a letter dated February 4, 2004
insisting upon a “hearing where I can present evidence,
ask questions and view the verification documents
called for in the law. Awaiting your response for the
date and time of such in person hearing.”
On February 6, 2004 this Appeals Officer responded to
your correspondence informing you of the conditions
under which you would be given an in person hearing,
otherwise we would continue with correspondence or by
telephone. You did not respond to this letter.
Balancing Efficient Collection and Intrusiveness
IRC Sec. 6330 requires that the Appeals Officer con-
sider whether any collection action balance the need
for efficient tax collection with the legitimate con-
cern that any collection action be no more intrusive
than necessary. The levy action is appropriate in that
you have only made time worn arguments against the tax
laws to evade the payment of tax nor are you in compli-
ance with the filing of your returns. It is inappro-
priate to allow you to ignore his [sic] tax obligations
any longer.
Petitioner filed a petition with the Court with respect to
the notice of determination relating to petitioner’s unpaid
liability for 1999. The petition contained statements, conten-
tions, arguments, and requests that the Court finds to be frivo-
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Last modified: May 25, 2011