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Petitioner attached a letter to his hearing request in which
he alleged: (1) He had received no taxable income and had no
taxable activity and thus had no filing requirement; (2)
respondent had not prepared proper substitute for returns under
section 6020(b) in that they were not signed by the Secretary and
were not on a form approved by the Office of Management and
Budget (OMB); (3) the lien was fabricated; and (4) the assessment
was unlawful.
On May 29, 2003, respondent sent petitioner copies of Forms
4340, Certificates of Assessment, Payments, and Other Specified
Matters, for 1994-99. Petitioner sent numerous letters to
respondent replete with the arguments described above and
additional arguments including: (1) Respondent failed to provide
him with Form 23C, Assessment Certificate - Summary Record of
Assessments; (2) imposition of the lien was a denial of due
process; and (3) respondent’s agents who worked on petitioner’s
case should be prosecuted.
On October 31, 2003, respondent sent petitioner a Notice of
Determination Concerning Collection Actions under section 6320
and/or 6330, in which respondent stated that all applicable laws
and administrative procedures had been met and that collection
from petitioner of his tax liability for 1994-99 would proceed.
Respondent determined that petitioner had raised only frivolous
issues and warned petitioner that he may be held liable for a
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