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that the settlement officer grant them a face-to-face hearing,
that, at the hearing, the settlement officer produce a multitude
of documents (many of which were, once again, irrelevant to the
section 6330 hearing), and that the settlement officer be
prepared to discuss at the hearing petitioners’ frivolous and
groundless arguments. Petitioners did not offer a collection
alternative at any point in their correspondence with the
settlement officer.
On April 21, 2005, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Sections 6320
and/or 6330 (notice of determination) regarding petitioners’
unpaid 1997 and 1998 income tax liabilities. In the notice of
determination, respondent determined that the proposed levy
should be sustained because petitioners had “failed to provide
[respondent] with an alternative collection that satisfies
[petitioners’] liabilities.”
On May 23, 2005, petitioners timely filed a petition for
lien or levy action under section 6320(c) or 6330(d) appealing
respondent’s determination to proceed with collection of
petitioners’ 1997 and 1998 tax liabilities. Petitioners asserted
that they had been denied a section 6330 hearing and repeated
several frivolous and groundless arguments they had raised in
their correspondence with the settlement officer.
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Last modified: May 25, 2011