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collect the unpaid tax liabilities. In this regard, respondent
initiated a Collections and Due Process (CDP) case under section
6330. In his petition and CDP hearing, petitioner continued to
argue that his compliance with the Federal tax system was
voluntary. He did not raise any other issues aside from his
contention that he should not have to pay taxes due to the
voluntary and inherently unfair nature of the Federal tax system.
He did not proffer any spousal defenses pursuant to section 6015,
challenge the appropriateness of the collection action, or offer
any collection alternatives pursuant to section 6330(c)(2).
In his petition to the Court and his objection to
respondent’s pending motion, petitioner continues to defend his
refusal to pay his income tax liabilities until respondent
“produces the law that states he is liable for the tax.”
Respondent’s present motion for summary judgment leads the
Court to consider the following issues:
(1) Whether respondent met all of the legal and
administrative requirements for the proposed collection action.
We hold that he has.
(2) Whether petitioner conceded respondent’s determination
that the proposed collection action was not more intrusive than
necessary. We hold that he has.
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Last modified: May 25, 2011