Charles and Teresa Brodman - Page 7

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          Internal Revenue Service has complied with code and procedural              
          requirements in collecting the tax.”                                        
               In the petition in this case, signed by Mr. Jewett,                    
          petitioners again challenge the authority of the officers issuing           
          the notice of deficiency, the notice of intent to levy and the              
          notice of lien, and the procedures by which the Appeals officer             
          verified the validity of the assessment; claim that they were               
          entitled to challenge the underlying liabilities because they               
          received no valid notice of deficiency; and assert that no                  
          provision of the Internal Revenue Code makes them liable for the            
          income tax and penalties determined in the statutory notice.  The           
          same arguments were repeated in petitioners’ trial memorandum               
          signed by Mr. Jewett and filed with the Court.                              
               On May 30, 2003, Mr. Jewett and counsel for respondent                 
          placed a conference telephone call to the Court in one of the               
          essentially identical cases on the Cleveland, Ohio, June 2, 2003,           
          calendar in which Mr. Jewett represented taxpayers.1  The                   
          conference telephone call concerned the desire of the taxpayers             
          in one of Mr. Jewett’s cases to withdraw him as counsel and to              
          work with the IRS in attempting to resolve their tax liability.             
          During the conference telephone call, the Court advised                     

               1  Three of those cases were submitted fully stipulated and            
          are in the same posture as this case.  James Benson and                     
          Melanie A. Dunham, docket No. 7029-02L; Gregory R. Brown, docket            
          No. 8368-02L; Harold V. and Imogene N. Pahl, docket No.                     
          11572-02L.                                                                  





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