Gary Wright - Page 3

                                        - 3 -                                         
          of balance due were sent to petitioner with respect to each year            
          on that date and on November 17, 1997.                                      
               On May 7, 2003, respondent issued to petitioner a Final                
          Notice of Intent To Levy and Notice of Your Right to a Hearing              
          with respect to his unpaid liabilities for 1993 and 1994.                   
          Petitioner timely submitted to respondent a Form 12153, Request             
          for a Collection Due Process Hearing, with attachments, setting             
          forth his disagreement with the proposed levy.  He stated on the            
          Form 12153:  “Don’t owe any money”, and listed on the attached              
          sheets enumerated documents (pertaining to, among other things,             
          underlying tax liability, assessment, notice and demand for                 
          payment, and verification from the Secretary that the                       
          requirements of any applicable law or procedure had been met)               
          that he requested be provided at the hearing before he would be             
          “persuaded that I am legally obligated to pay the taxes at                  
          issue.”  He also asserted that he would be recording the hearing            
          pursuant to section 7521(a)(1).                                             
               By a letter dated October 8, 2003, Michael A. Freitag, the             
          settlement officer to whom petitioner’s case had been assigned,             
          explained that the Internal Revenue Service (IRS) Office of                 
          Appeals did not provide face-to-face hearings where the only                
          items for discussion raised by the taxpayer were those deemed by            
          the courts to be frivolous or groundless.  Accordingly, Mr.                 
          Freitag scheduled a telephone conference for November 4, 2003,              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011