-3- Petitioner relied on the following as the basis of his case: (a) The Examiner, who is the Revenue Officer moved a collection activity in violation to Title 26, CFR part 601.104 (b) The Technical Services Officer knows and/or should have known that a non statutory collection activity is demonstrative of an inappropriate collection activity. (Title 26 of USCA Chapter 64, Subchapter D) (c) The Examiner’s Tax Payer Delinquency Investigation substantiates it has moved an inappropriate collection activity, that stands in contradistinction to the Paper Work Reduction Act. (Title 26 CFR part 601.101) (d) The Technical Services Territory Manager is attempting to perfect an inappropriate collection action, as it is unwilling, and/or unable to produce a lawfully filed, and/or legally executed TAX RETURN. (Title 26 USCA Chapter 63, Subchapter A) Respondent filed a motion to dismiss the case for failure to state a claim upon which relief can be granted. On October 21, 2005, the Court ordered petitioner to file an amended petition “in which petitioner sets forth with specificity each error petitioner alleges was made by respondent in the determination of the deficiency and additions to tax, and separate statements of every fact upon which petitioner bases the assignment of errors.” On November 2, 2005, petitioner filed with this Court an amended petition in which he listed the following assignments of error of respondent: a.) The respondent failed to substantiate a lawful collection of information for the issuance of statutory notice of deficiency.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011