-7-
If we do not hear from you by May 3, 2001, we may
take enforcement action without notifying you further.
On May 6, 2001, the Ogden Service Center received from
petitioner two signed Forms 12153 for 1990, 1991, and 1992, and
for 1995, respectively, which stated:
This Form 12153 WAS NOT SIGNED VOLUNTARILY, but
UNDER DURESS, not wishing to give the I.R.S. or it’s
agents any cause to deny or delay the Due Process
Hearing guaranteed to me by law as per I.R.C. Section
6330. My signature on this document DOES NOT give even
TACIT AGREEMENT that the “statutory period of
limitations for collection be suspended during the
Collection Due Process Hearing and any subsequent
judicial review”.
On September 28, 2001, the Appeals officer held with
petitioner an equivalent hearing. At the equivalent hearing, the
Appeals officer explained to petitioner that it was an equivalent
hearing and not a Hearing. The Appeals officer then reviewed and
showed to petitioner Forms 4340, Certificate of Assessments,
Payments and Other Specified Matters. The Forms 4340 were dated
July 17, 2001, and were for 1990, 1991, 1992, and 1995. On
September 28, 2001, after the equivalent hearing, the Appeals
officer sent the Forms 4340 to petitioner.
On October 27, 2001, the Appeals officer issued to
petitioner a “Decision Letter Concerning Equivalent Hearing Under
Section 6320 and/or 6330" (i.e., the decision letter) for 1990,
1991, 1992, and 1995. The decision letter sustained the proposed
collection action against petitioner. The decision letter stated
that petitioner did not have the right to judicial review of the
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