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                  
          petitioner’s documents.                                                     
               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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