- 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. Discussion 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 thePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011