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this Court.2 Respondent timely assessed petitioner for the tax,
additions to tax, penalties, and interest for the years in issue.
On November 28, 2002, respondent sent petitioner a Letter
1058, Final Notice of Intent to Levy and Notice of Your Right to
a Hearing. Petitioner timely filed Form 12153, Request for a
Collection Due Process Hearing, on December 19, 2002.
Respondent’s Appeals Officer Gayla L. Owens conducted
petitioner’s hearing on November 12, 2003. Petitioner raised
only frivolous tax protester type arguments at the hearing,
arguing that he did not have gross income as defined by sections
861, 911, and section 1.861-8(a)(4), Income Tax Regs. Petitioner
also stated at the hearing that his First Amendment, Fifth
Amendment, and Sixth Amendment individual rights had been
violated; that he was denied meaningful due process of law; and
that decisions by lower courts, such as this Court and the
Federal District Courts, are binding on the Internal Revenue
Service only for the particular taxpayer and years litigated.
On November 19, 2003, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 sustaining the proposed levy to collect petitioner’s
unpaid tax liabilities for the years in issue. On December 16,
2003, petitioner timely filed his petition with this Court, again
2 Petitioner does not dispute that he received the notices
of deficiency.
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Last modified: May 25, 2011