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B. Hearing Before an Independent and Impartial Hearing
Officer
In the petition, petitioner claims he was not afforded a
hearing before an independent and impartial hearing officer. If
petitioner’s complaint is that Appeals Officer Gonzales was not
independent and impartial, see sec. 6330(b)(3), petitioner did
not pursue that issue at trial. Therefore, we assume, that he
has abandoned that issue, and we shall not further discuss it.
See, e.g., Bernstein v. Commissioner, 22 T.C. 1146, 1152 (1954),
affd. 230 F.2d 603 (2d Cir. 1956); Lime Cola Co. v. Commissioner,
22 T.C. 593, 606 (1954).
C. No Harm in Fact
Moreover, as to any other complaint of petitioner with
respect to the notice, we note that, at trial, the Court had an
extended discussion with petitioner concerning the exact nature
of the claim that brought him to this Court. Petitioner agreed
more than once that he had been afforded the opportunity for a
hearing. His only claim was that he had no tax liability because
his indebtedness to the Internal Revenue Service had been assumed
by the Federal government:
MR. WATSON: That House Joint Resolution 192 of
June 5th and 6th, 1933, which was the suspension of the
gold standard specie which kept the nation stable only
discharged the debt, not pay debt.
Under House Joint Resolutions, all debts, public
and private, the Government agreed to assume.
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