Aaron T. and Linda K. Ball - Page 4

                                        - 4 -                                         
               On July 26, 2004, petitioners sent a letter to the                     
          settlement officer requesting a face-to-face conference in Las              
          Vegas, Nevada.  In that letter, petitioners continued to assert             
          frivolous and/or groundless arguments for why they are not liable           
          for income taxes.  Respondent did not allow petitioners a face-             
          to-face meeting.                                                            
               On August 6, 2004, respondent issued petitioners a Notice of           
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330, in which the settlement officer sustained the                  
          proposed levy to collect petitioners’ unpaid 1997 tax liability.            
          Petitioners filed a petition for lien and levy action on                    
          September 13, 2004.  Petitioners alleged that they were not                 
          provided with a hearing under section 6330.                                 
               At trial, petitioners continued to make frivolous and/or               
          groundless arguments that they are not liable for Federal income            
          tax.  Respondent sought sanctions under section 6673.                       
          I.  Determination To Proceed With Collection                                
               Section 6331(a) provides that, if any person liable to pay             
          any tax neglects or refuses to do so within 10 days after notice            
          and demand, the Secretary can collect such tax by levy upon                 
          property belonging to such person.  Pursuant to section 6331(d),            
          the Secretary is required to give the taxpayer notice of his                
          intent to levy and within that notice must describe the                     

Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011