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In March 1996, petitioner and an unidentified individual
visited (March 1996 meeting) the office of a revenue officer of
the Service (revenue officer) who was responsible for conducting
investigations of delinquent returns and collecting unpaid taxes.
Petitioner asked the revenue officer for permission to tape the
March 1996 meeting, but the revenue officer declined because the
revenue officer did not have equipment readily available with
which he also could have taped that meeting. However, the
revenue officer informed petitioner that if petitioner were to
give him 10 days' written notice, he could arrange another
meeting that could be taped. Petitioner informed the revenue
officer at the March 1996 meeting that there were certain civil
penalties that he wanted to have abated by the Service that arose
from his having submitted Forms 1040NR. The revenue officer
asked petitioner at the March 1996 meeting if he was a U.S.
citizen or a nonresident alien. Petitioner responded that he was
both. The revenue officer told petitioner that he had to be one
or the other, but that he could not be both.
The revenue officer also advised petitioner at the March
1996 meeting that the Service's records indicated that he had not
filed returns for 1992, 1993, and 1994 and that the Service had
records from payors of income to petitioner, which indicated that
petitioner had substantial income for those years.3 Petitioner
3 As of the time of the March 1996 meeting, petitioner's
(continued...)
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