- 11 - productive. See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001); Ho v. Commissioner, supra. Additionally, petitioner argues that respondent abused his discretion by failing to verify that all administrative procedures have been met. However, in the notice of determination, the Appeals officer verified that all requirements of applicable law and administrative procedure had been met, and he properly balanced the need for efficient collection against the intrusiveness of the collection action. Petitioner points to nothing that indicates respondent failed to follow applicable law and administrative procedure. Petitioner further argues that respondent abused his discretion by failing to make a notice and demand for payment. However, the Forms 4340 indicate that notices and demands for payment were made. Petitioner also raises various tax-protester arguments, including: (1) The income tax is unconstitutional; (2) he is not a U.S. citizen, but instead “an American man living on the soil of Massachusetts”; (3) letters received from respondent do not include signatures or “Publication No. 594”; and (4) he has not been provided with proof that the person(s) who issued the notice of Federal tax lien had the authority to do so. Petitioner’s arguments have been rejected by this Court and other courts, and “We perceive no need to refute these arguments with somberPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011