-3-
telephonic hearing with petitioner during which he repeated the
aforementioned allegations. On November 3, 2005, Appeals issued
to petitioner the notice of determination underlying this case.
That notice of determination sustained respondent’s filing of the
tax lien. On December 2, 2006, petitioner petitioned the Court
with respect to the notice of determination alleging as his sole
ground for error “Racism by the Court”.
OPINION
Section 6320 provides that the Secretary shall furnish the
person described in section 6321 with written notice of the
filing of a notice of lien under section 6323. Section 6320
provides further that the taxpayer may request that Appeals
review the matter in an administrative hearing. Pursuant to
section 6330(c)(2)(A), as made applicable by section 6320(c), a
taxpayer may raise at the hearing any relevant issue with regard
to the Commissioner's collection activities, including spousal
defenses, challenges to the appropriateness of the Commissioner's
intended collection action, and alternative means of collection.
See Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v.
Commissioner, 114 T.C. 176, 180 (2000).
Appeals held the requisite hearing with petitioner and
issued its determination sustaining the propriety of the lien.
Because petitioner received notices of deficiency for the subject
years, and hence is precluded from challenging his underlying tax
Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011