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Background
On May 3, 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 tax for 1997.1 Respondent’s Office of Appeals
determined that it was appropriate to collect petitioner’s unpaid
taxes by levy. On May 31, 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 1997. I believe that
it has been 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?
I need the help of the Tax Court to clarify this
matter. I am unclear as to what rules of procedure and
evidence were to preside over my Collection Due Process
Hearing. Although I asked many times I never received
any information on such procedures. The agent was no
help at all.
Now a whole new procedure is beginning and I am more
confused. I am unsure of what to do from here. Will
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year 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