- 4 - 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 “aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011