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Settlement Officer Powell then verified that he had no prior
involvement with the unpaid income tax at issue, that petitioner
had an unpaid income tax liability for taxable year 2001, and
that respondent met the requirements of all applicable laws and
administrative procedures. Settlement Officer Powell considered
whether the proposed collection action balanced the need for the
efficient collection of taxes with the concern of petitioner that
any collection action be no more intrusive than necessary.
Petitioner did not raise, and, consequently, Settlement Officer
Powell did not consider, any challenges to the appropriateness of
the collection actions or offers of collection alternatives.
On May 11, 2004, respondent issued a notice of determination
sustaining the proposed levy. In response, petitioner timely
petitioned this Court.1 The petition states in part:
The person involved in the determination has not answered
any on my question. I have exhausted my ability to keep
asking when they the IRS just acts like I am sheep they can
run over. I will not ask any more, when they should have
already answered my request. I have called, and called, and
I can’t even get a response, other than one agent told me,
“you owe this because my computer says you owe it.” One of
the other agents I talked to told me,”I am the IRS I can
take your property anytime I want too”. Well I guess this is
where we are going, we are going to see just how it works.
the rest of my research is on the other 5 pages. I was
1Petitioner incorrectly marked the area of the Court’s
standard petition form used to identify the type of action
sought. Petitioner indicated that it was a Petition for
Redetermination of a Deficiency. The Court has treated this
pleading as a Petition for Lien or Levy Action (Collection
Action).
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Last modified: May 25, 2011