Thiele L. Wetzel - Page 5

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          amounts that could not be computed at the time of the                       
          determination.  Petitioner did not file a petition with this                
          Court.                                                                      
               Petitioner stamped the notice of deficiency “Refused for               
          Fraud F.R.C.P. 9(b)” and returned it to respondent with an                  
          attachment in which petitioner alleged: (1) The notice of                   
          deficiency was fraudulent; (2) he did not receive notice of the             
          examination; (3) he is not liable for tax; and (4) respondent               
          failed to prepare proper substitutes for returns.                           
          D.   Notice of Federal Tax Lien                                             
               On January 22, 2003, respondent filed a notice of Federal              
          tax lien relating to petitioner’s unpaid income tax liabilities             
          of $14,777.63 for 1994, $9,035.91 for 1995, $9,316.57 for 1996,             
          $11,563.38 for 1997, $7,871.54 for 1998, and $13,809.37 for 1999.           
          On January 27, 2003, respondent sent petitioner a notice that the           
          notice of Federal tax lien for 1994-99 had been filed.                      
               Petitioner timely requested a hearing under sections 6320              
          and 6330 on February 25, 2003.  In the hearing request,                     
          petitioner claimed that he was not a “taxpayer” as defined in the           
          Internal Revenue Code or by any regulation thereunder, and he               
          asked: (1) What, if any Federal tax liability does he have? (2)             
          for which Federal tax is he liable? (3) what action made him                
          liable for Federal tax? (4) why was he not told that he owed                
          Federal tax? and (5) who assessed the Federal tax?                          






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