Judith Walther - Page 2

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               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              

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