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Background
On October 5, 2005, respondent issued to petitioner a Notice
of Determination Concerning Collection Actions(s) Under Section
6320 and/or 6330 (notice of determination) regarding her unpaid
Federal income taxes for 2001 and 2002.1 Respondent’s Office of
Appeals determined that it was appropriate to collect
petitioner’s unpaid taxes by levy. On November 2, 2005,
petitioner sent to the Court a document, which states in relevant
part:
Dear Tax Court,
I received a notice of determination letter from the
IRS for tax years 2001 and 2002. Their letter states I
must file a petition with the United States Tax Court
within 30 days from Oct. 5, 2005 if I want to dispute
the determination. Please consider this as that
petition and a protest.
I was denied an in person due process hearing and
though I asked several times none of my concerns or
questions were answered by anyone at the IRS. It
appeared as if I was writing to a computer that didn’t
have the capacity to think or reason. The agent, if
there really was one, was absolutely no help to me.
They appear extremely uncooperative in even the most
basic matters.
I asked them to show me how I could owe taxes when I
didn’t have a job and am on disability. I do not
believe I owe them anything for any year.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011