- 4 - denied a due process hearing, all I got was a phone call and they made up the rest in the notice of determination. Petitioner attached five additional pages to the petition which include the following: (1) Numerous citations to Federal and Supreme Court cases; (2) quotes from various Congressional proceedings, including a Senate hearing regarding formation of the UN; (3) a quote from John Maynard Keynes about inflation; and (4) various Code sections. Petitioner’s response to the instant motion and statements at the hearing on the motion contain similar arguments, including: (1) The definition of frivolous; (2) quotes from Thomas Jefferson and George Washington; (3) citations of various sections of the Internal Revenue Code and the Regulations; (4) an argument based on the Sixth Amendment; (5) a section 861 argument often advanced by tax protesters; and (6) various religious statements. Discussion Rule 331(b)(4) requires that a petition in a levy action contain “Clear and concise assignments of each and every error which the petitioner alleges to have been committed in the notice of determination. Any issue not raised in the assignments of error shall be deemed to be conceded. Each assignment of error shall be separately lettered.” Rule 331(b)(5) further requires that the petition contain “[c]lear and concise lettered statements of the facts on which the petitioner bases eachPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011