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Under Section 6320 and/or 6330. The notice of determination
provided in pertinent part:
We advised that some of the issues raised in your
appeal were of a frivolous nature. We advised that
this was your opportunity to discuss why you believed
you did not owe the tax and/or why you could not pay
the tax liability. You advised that you believe you
were assessed additional tax because your election for
S-corporation status was denied. You stated that you
believed that the denial was in error and that the IRS
granted this status in 1999. Your representative
advised that you could not pay the tax because you had
received threats on your life.[4] You have not advised
as to how the alleged death threats have impacted your
ability to pay the tax liability.
The notice of determination stated that petitioner did not
provide the requested information and documentation to Ms.
Derrick. It further provided that “Although a levy is intrusive,
you have not provided financial data that would allow our office
to consider a viable collection alternative”. The Form 4340,
Certificate of Assessments, Payments, and Other Specified
Matters, for taxable year 2000, attached as an exhibit to the
joint stipulation of facts in this case, was not obtained until
after the notice of determination was issued. Petitioner filed a
4Mr. Dahlin’s former legal assistant and office manager
solicited a “hitman” to murder him. Respondent objected, based
on relevancy, to the admission into evidence of a newspaper
article that discussed the solicitation of first degree murder by
Mr. Dahlin’s former employee and the subsequent trial. See Fed.
R. Evid. 401. The Court concludes that while the relevancy of
the newspaper article is certainly limited, it meets the
threshold definition of relevant evidence and is admissible. The
Court will give the article only such consideration as is
warranted by its pertinence to the Court’s analysis of the case.
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Last modified: November 10, 2007