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Specified Matters, for his 2001 tax year. During the conference,
petitioner renewed his requests for the underlying assessment
documents and that the Appeals officer provide petitioner with a
copy of the statute that made him liable to pay any income taxes.
On February 3, 2006, the Appeals Office issued the Notice of
Determination from which petitioner petitioned to this Court.
In petitioner’s hearing request, and in addition to his 2001
tax year, petitioner included numerous taxable years that were
not the subject of timely requests for a hearing. In that
regard, petitioner requested a hearing with respect to his 1999
and 2000 tax years, but the notices of intent to levy and Federal
tax lien filing for those years were sent to petitioner in 2004
(more than 1 year prior to petitioner’s hearing request).
Petitioner also requested a hearing with respect to his 1996,
1997, and 1998 tax years, but there was no balance of tax then
due and no pending collection or proposed collection action.
With respect to the 1999 and 2000 tax years, the Appeals officer
advised petitioner that they would be handled as “Equivalent
Hearings” (hearings without a right of appeal or review by this
Court).
Discussion
Issues for Consideration
The Petition and Amended Petition in this case, in essence,
contain the following allegations/issues: (1) Respondent’s
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