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Background
At the time of the filing of the petition, petitioner
resided in Bloomingdale, Georgia.
On March 30, 2003, respondent issued to petitioner a Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing for tax year 2001. In response, petitioner timely
requested a hearing by filing Form 12153, Request for Collection
Due Process Hearing, citing frivolous arguments in support of his
request.
During the Appeals process, Settlement Officer Powell had a
telephone conversation with petitioner in which he requested a
face-to-face hearing in Savannah, Georgia. Respondent’s Office
of Appeals had previously sent a letter to petitioner stating
that petitioner would not receive a face-to-face hearing unless
he had nonfrivolous issues to discuss but instead would receive a
hearing by telephone and/or correspondence. When Settlement
Officer Powell asked what issues petitioner would discuss at a
face-to-face hearing, petitioner said he wanted to discuss the
law that forces him to pay tax. Settlement Officer Powell
informed petitioner that the issue was frivolous and he would
therefore only receive a telephone or correspondence hearing.
Petitioner then stated that, if he did not receive a face-to-face
hearing in Savannah, Georgia, he did not want a hearing.
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Last modified: May 25, 2011