- 3 - On April 19, 2005, petitioner sent respondent a Form 12153, Request for a Collection Due Process Hearing. Respondent’s Appeals officer reviewed petitioner’s correspondence and determined that all of petitioner’s contentions were frivolous. On July 25, 2005, respondent’s Appeals officer sent petitioner a letter in which respondent notified petitioner that respondent had received petitioner’s request for a section 6330 hearing and scheduled a telephone conference for August 17, 2005, at 3 p.m. The letter advised petitioner that the underlying liabilities could not be raised at the hearing because petitioner had received statutory notices of deficiency.2 Respondent’s letter also directed petitioner to an Internal Revenue Service (IRS) publication, “The Truth About Frivolous Tax Arguments”, available on the IRS’s Web site. Finally, the letter advised petitioner of this Court’s authority to impose a sanction of up to $25,000 pursuant to section 6673. Petitioner did not respond to this letter and failed to participate in the scheduled phone conference. On August 22, 2005, respondent sent petitioner a letter again requesting that petitioner contact respondent and provide any additional 2Petitioner denies receiving a statutory notice of deficiency. However, this is only because petitioner claims to have received “non-statutory” notices of deficiency. Accordingly, the fact of receipt is deemed conceded.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011