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not be granted a face-to-face hearing. Mrs. Magee also scheduled
a telephonic conference for February 15, 2006.
Petitioner failed to participate in the telephonic
conference. Instead, petitioner faxed a 17-page document
entitled “Public Protection Clause” to Mrs. Magee. This document
contained only frivolous tax protester arguments.
On February 16, 2006, Mrs. Magee sent a letter to petitioner
stating that since he did not participate in the telephonic
conference she would make a decision in his case on the basis of
the administrative file and any material he had submitted. The
letter gave petitioner the opportunity to submit any additional
information within 14 days. Petitioner did not avail himself of
this opportunity.
In his submissions to the IRS, petitioner raised only
frivolous challenges to the underlying liability. Petitioner did
not offer any collection alternatives for Mrs. Magee to consider.
After verifying that all applicable laws and administrative
procedures had been met, Mrs. Magee determined, on the basis of
the administrative file, that the proposed levy balanced the need
for efficient collection of taxes with the legitimate concern
that any collection action be no more intrusive than necessary.
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Last modified: May 25, 2011