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totaling $81,287.21. Petitioner requested a section 6330
hearing. Attached to his request was a document entitled “Notice
of Appeal, Challenge and Objection, Request for Production of
Documents, Demand for Hearing and Judicial Review, and
Counterclaim and Offset and To Dismiss Notice”. In that
document, petitioner set forth a melange of claims, including
that the Revenue officer had failed to make available to him
payment plans; that the IRS had erroneously granted relief to his
former spouse; that 2003 and 2004 liabilities were not properly
the subject of levy; that petitioner was not liable for penalties
and interest; that petitioner had a counterclaim and offset for
property taken from him when he was a minor; and numerous vague
and unsupported claims of violation of procedural regulations,
due process, and equal protection. Petitioner requested a face-
to-face hearing close to his residence. In a letter dated
September 11, 2005, he explained his position that he had sold
cattle herds during 2000 to meet the demands of his former wife,
who started divorce proceedings in 1999. He stated: “It is my
understanding that my ex-wife was granted innocent spouse status
about July 2003 even though she is the one that spent all the
money and that is the reason the two cattle herds had to be
sold.” Petitioner requested that the hearing be delayed because
of his domestic situation and his professional responsibilities.
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Last modified: November 10, 2007