- 5 - 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 casePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011