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told the revenue officer that he had only approximately $2,000 to
$3,000 of income for 1992.
At the March 1996 meeting, petitioner told the revenue
officer that he had asked the Service many times to show him what
provision in the Code required him to file returns, and he asked
the revenue officer to specify the sections in the Code and the
regulations that required him to file returns. The revenue
officer pointed out to petitioner that a notice issued by the
Service, which petitioner had brought with him to the March 1996
meeting, informed taxpayers that sections 6011 and 6012 required
taxpayers to file returns. The revenue agent was not able to
cite for petitioner at the March 1996 meeting the specific
sections of the regulations under those Code sections that
elaborated on those filing requirements.
The revenue officer told petitioner at the March 1996
meeting to send him a written request for abatement of the civil
penalties, which showed reasonable cause as to why the Service
should abate those penalties, and to submit his delinquent
returns for 1992, 1993, and 1994. The revenue officer informed
petitioner that he would request that petitioner's request for
abatement and delinquent returns be assigned to him, since he was
having the March 1996 meeting with petitioner and thus was
familiar with those matters.
3 (...continued)
return for 1995 was not yet due.
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