- 5 - 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?Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011