-4-
for records made under the Freedom of Information Act, 5 U.S.C.
sec. 552 (2000), records he stated were necessary to prove the
disagreements set forth in petitioners’ request for the hearing,
and (2) anticipating challenging in court a statement by the
Appeals officer that only an attorney, certified public
accountant, or enrolled agent could represent them at the
hearing.
On May 18, 2000, the Appeals officer mailed to petitioners a
letter stating that the hearing had been rescheduled for June 20,
2000. The letter also stated that, if petitioners desired, the
Appeals officer would reschedule the hearing for a date before,
but not after, June 20, 2000. The letter informed petitioners
that the Appeals officer would make his determination on the
basis of the information in the file if petitioners were unable
to attend a face-to-face hearing before June 21, 2000. Enclosed
with the letter were certified transcripts, Forms 4340,
Certificate of Assessments and Payments, of petitioners’ accounts
for 1993, 1995, and 1997, and a copy of Circular 230 which, the
letter stated, “presents the Regulations governing practice
before the Internal Revenue Service.”
On June 3, 2000, Mr. Bartschi responded to the Appeals
officer’s latest correspondence with a letter requesting again
that the Appeals officer reschedule the hearing for the last week
of July. This letter stated that petitioners were anticipating
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Last modified: May 25, 2011