William M. Leggett - Page 4

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          Section 6320 and/or 6330 for the years in issue on July 15, 2004.           
          The attachment to the notice stated that the levy was                       
          “appropriate and reasonable under the circumstances thereby                 
          balancing the need for efficient collection of the taxes while              
          not being any more intrusive than necessary.”  It also indicated            
          that petitioner’s unpaid tax liabilities for 1994, 1995, and                
          1996, were $77,311.19, $16,470.89, and $23,277.75, respectively,            
          as calculated through July 15, 2004.                                        
               Petitioner timely petitioned this Court for review of the              
          collection action.  Petitioner argued in the petition that “the             
          IRS violated petitioner’s right to procedural due process by                
          refusing allow [sic] him to make an administrative record by                
          recording the telephone conference on July 12, 2004.”  Petitioner           
          also contended that “the IRS failed to comply with the provisions           
          of 26 U.S.C. Section 6321/31", that “the assessments for the tax            
          period [sic] 1994, 1995, and 1996 are invalid”, and that “the IRS           
          lost its administrative collection powers by failing to comply              
          with the notice requirements of 26 U.S.C. Section 6303.”                    
               In addition, petitioner filed a posttrial brief which stated           
          he did “not and has not engaged in an activity that produces                
          ‘TAXABLE INCOME’, but only an exchange of intellectual and                  
          physical property for an agreed upon perceived value in the only            
          medium of exchange of the day i.e. FRN’s [Federal Reserve                   
          Notes]”.  Petitioner’s brief also stated that petitioner is “a              






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