M. Kenneth Creamer - Page 5
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Concerning Collection Action(s) Under Section 6320 and/or 6330
sustaining respondent’s proposed collection actions.4
By letter dated July 25, 2006, petitioner sent Settlement
Officer Smith a package of documents5 which included, among other
things, statements of various frivolous arguments asserted by
petitioner6 and copies of Federal income tax returns for 1991
through 1998 and 2002 that showed zero income and zero tax
On August 30, 2006, the petition in this case was filed.
The petition alleges: (1) Respondent did not provide evidence
that petitioner was engaged in “employment” or a “trade or
business” as defined by the Internal Revenue Code; (2) respondent
failed to execute a valid substitute return under section
6020(b); (3) respondent does not have authority to execute a
substitute for return; and (4) petitioner filed tax returns for
each year at issue showing no tax liability.
4Respondent also issued petitioner a Decision Letter
Concerning Equivalent Hearing Under Section 6320 and/or 6330
ruling that respondent’s notice of lien may remain on file.
5The record is unclear as to when respondent received
6Petitioner asserted that his wages were not taxable income
because he was not engaged in “employment” or a “trade or
business” as defined in the Internal Revenue Code. Petitioner
also challenged respondent’s authority to levy upon his property
and to prepare substitutes for returns.
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Last modified: November 10, 2007