- 4 - Secretary delegated authority to various IRS directors and employees involved in petitioner’s case. Mr. Lawrence Phillips, the settlement officer assigned to petitioner’s case, mailed petitioner a letter dated July 20, 2004, that advised petitioner on the procedures of a collection hearing. The letter warned that “items that you mention in your CDP request are items that: 1. Courts have determined are frivolous or groundless, or 2. Appeals does not consider. These are moral, religious, political, constitutional, conscientious, or similar grounds.” Mr. Phillips further enclosed with the letter copies of Forms 4340, Certificate of Assessments, Payments, and Other Specified Matters, for 1999 and 2000. The collection hearing was held via telephone on August 5, 2004. During the hearing petitioner again demanded documentation and reiterated tax-protester rhetoric. Petitioner also questioned Mr. Phillips as to why his hearing was being conducted by a settlement officer and not an Appeals officer. On August 18, 2004, respondent mailed to petitioner the above-mentioned Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 for the 1999 and 2000 taxable years. Petitioner timely filed a petition with this Court for redetermination of the collection action. Therein, in addition to contentions akin to those set forth in his Form 12153, petitioner argued: (1) Notices of Deficiency that arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011