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will determine whether the Court has jurisdiction to decide
whether the proposed collection against petitioner may proceed.
At all relevant times, petitioner resided in Omaha, Nebraska.
Background
On September 16, 2005, respondent issued to petitioner a
Notice of Determination Concerning Collection Actions(s) Under
Section 6320 and/or 6330 (notice of determination) regarding his
unpaid Federal tax liabilities for 1999 and 2001.1 Respondent’s
Office of Appeals determined that it was appropriate to collect
petitioner’s unpaid taxes by levy. On October 14, 2005,
petitioner sent to the Court a document, which states in relevant
part:
Dear Tax Court Judge,
The Collection Due Process Hearing that I requested has
been decided. I need your assistance regarding a
Notice of Determination I received from the Internal
Revenue Service for the tax year 1999 and 2001. I
believe that this hearing was unfair and biased. I was
not provided information that I requested from the
hearing agent.
The letter states that I must file a petition with the
U.S. Tax Court if I believe the IRS numbers are wrong.
I think the IRS is wrong but I am not sure if I am
doing this protest right. I told the IRS I didn’t owe
them anything and they still have not shown me any
proof to support their claim. Could you please write
to me and let me know the procedure?
1 Unless otherwise indicated, 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