The bolding is mine. I wonder where she got that from?Judge Foley wrote:Petitioner failed to file her 2006 Federal income tax return, and respondent,
pursuant to section 6020(b), prepared a substitute for return. Respondent, on June
5, 2009, sent petitioner a notice of deficiency, and on May 3, 2010, sent petitioner
a Notice of Intent to Levy and Notice of Your Right to a Hearing relating to 2006.
On May 19, 2010, petitioner submitted a Form 12153, Request for a Collection
Due Process or Equivalent Hearing; attached a 16-page letter in which she
asserted that respondent lacked authority to file a substitute for return; and stated
that “the heart of this matter and appeal, is the lack of any statute which clearly
and unequivocally makes me liable for, or subject to, the federal income tax
imposed”.
In what is not a surprise to us,
I think we will be hearing more from her in the future.Judge Foley wrote:Petitioner raised frivolous issues in her CDP hearing request, did not raise
any relevant issues during the hearing, did not propose a collection alternative,
and did not provide requested documentation. Accordingly, respondent did
not abuse his discretion.
