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because he said he was obtaining documents under the Freedom of
Information Act that he said he might need in the hearing.
Petitioner also asked for copies of the Code section and
implementing legislative regulations that establish his
liability.
By letter dated July 26, 2000, Owens scheduled a hearing for
September 15, 2000, and again asked petitioner whether he
preferred a face-to-face conference or to handle it by telephone.
By letter dated August 18, 2000, petitioner told Owens that he
would not attend a hearing for which he was not allowed to
prepare, and that Owens had not responded to points he raised in
earlier letters to her. In that same letter, petitioner stated,
among other things, his views that: (1) The frivolous return
penalties are illegal; (2) respondent’s employees are subject to
punishment under section 7214(a) for violating the Internal
Revenue Service Restructuring and Reform Act of 1998, Pub. L.
105-206, 112 Stat. 685; (3) the IRS is required to sue him for
payment of the penalty; and (4) the IRS was harassing him.
Petitioner also asked for a statement acknowledging that he did
not question the constitutionality of the income tax when he
filed his amended returns for the years in issue. He wrote in
part:
Therefore, I am requesting that you comply with IRS
Code Section 6065 and send me a statement which “is
verified by a written declaration that is made under
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