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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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