Randy A. Belmont - Page 5

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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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