District Court, N.D. Ohio October 14, 2004, 1:04 CV 1840 (Bartley v. United States Internal Revenue Service)

MEMORANDUM OF OPINION

O’MALLEY, District Judge.

On September 10, 2004,

pro se

plaintiff Jason Bartley filed this action against the

*650

Internal Revenue Service (IRS). Mr. Bartley is seeking to set aside a Notice of Determination (“Determination”) issued by the I.R.S. Office of Appeals (Appeals Office) on August 12, 2004. He asserts that he is entitled to relief pursuant to 26 U.S.C.