- 5 - 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 liability. 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007