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arguments. Finally, the letter threatened that petitioner would
file a claim for damages of $200,000 against the Settlement
Officer personally.
By letter dated June 21, 2005, Mrs. Magee responded to
the June 17 letter, rescheduling the telephonic conference for
July 12, 2005, at 3 p.m. Mrs. Magee also informed petitioner
that the arguments in the June 17 letter were ones that courts
had held to be frivolous and would not be considered by
respondent’s Appeals Office. Mrs. Magee directed petitioner to
“The Truth About Frivolous Tax Arguments” on the IRS Web site.
In her letter, Mrs. Magee also explained that respondent’s
Appeals Office does not provide a face-to-face hearing if the
only items a taxpayer wishes to discuss are frivolous arguments.
Petitioner replied by letter, again requesting a face-to-
face hearing but not specifying any nonfrivolous issues to
discuss. Petitioner stated in the letter that he wished to
discuss the underlying liabilities.
On July 12, 2005, Mrs. Magee attempted a telephonic
conference with petitioner. Petitioner indicated that he was
speaking via a cell phone and said very little. The call was cut
off prematurely. When Mrs. Magee attempted to call petitioner
immediately thereafter, petitioner did not answer. Mrs. Magee
called three more times on July 12, 2005, and received no answer.
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