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prepared to discuss issues relevant to paying your tax
liability”, including collection alternatives.
On November 26, 2003, a face-to-face conference was held,
attended by Mr. Dolin and Settlement Officer Dale Roginski and
petitioner and petitioner’s wife Christina Belmont. Petitioner
provided a court reporter to record the hearing.
Throughout the conference, petitioner and his wife
persistently asked Mr. Dolin to prove he had the authority to
hold the hearing, questioned whether the IRS had the authority to
issue a tax lien, and raised other frivolous arguments. Although
Mr. Dolin attempted to explain the appeals process and discuss
collection alternatives, petitioner and wife refused to allow him
to do so. As a result, Mr. Dolin ended the conference.
Petitioner had not filed his 2000, 2001, and 2002 Federal income
tax returns at the time of the conference.
In the February 17, 2004, notice of determination mailed to
petitioner, Mr. Dolin determined that the filing of the NFTL was
proper and would be sustained. Mr. Dolin found that respondent
complied with all Code and procedural requirements in filing the
NFTL.
In response to the notice of determination, petitioner filed
a petition in the United States District Court for the Northern
District of Ohio on March 16, 2004. Because the District Court
lacked jurisdiction to hear the matter, it dismissed the case
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Last modified: May 25, 2011