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Action(s) Under Section 6320 and/or 6330, sustaining the proposed
levy action. An attachment to the notice addressed the
verification of legal and procedural requirements, the issues
raised by the taxpayer, and the balancing of efficient collection
and intrusiveness. According to the attachment, petitioner
“raised no non-frivolous issues.”
A document received by the Court from petitioner was filed
as a timely mailed petition disputing the notice of determination
on March 5, 2004, and an amended petition was filed on May 27,
2004. Both documents reflected an address in Las Vegas, Nevada.
In a statement attached to the amended petition, petitioner
complained principally about the failure of the IRS to provide a
face-to-face hearing and requested documentation. He espoused a
position that he was not liable for any taxes and prayed, inter
alia, that we order the IRS “to stop all illegal attempts to
extort money” from him.
This case was called from the calendar of the trial session
of the Court in Las Vegas, Nevada, on December 6, 2004, and a
trial was held on December 8, 2004. At the trial, petitioner
filed two motions identical in substance, one of which was titled
a motion to restrain assessment or collection and the other of
which was titled a motion to dismiss. In these motions,
petitioner essentially rehashed his arguments regarding lack of a
hearing and insufficient documentation. The Court took the
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Last modified: May 25, 2011