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1998 returns.
D. Respondent’s Final Notice and Petitioner’s Response
On October 10, 2000, respondent mailed to petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing in respect of his outstanding tax liabilities for 1997
and 1998.
On or about November 4, 2000, petitioner filed with
respondent Form 12153, Request for a Collection Due Process
Hearing. The request, which was accompanied by a typewritten
statement, included, inter alia, a challenge to the existence of
the underlying tax liabilities for 1997 and 1998, as well as
allegations that petitioner was never provided with a valid
notice of deficiency or notice and demand for payment and that
the Appeals officer had failed “to identify the statute that
makes me ‘liable to pay’ the taxes at issue”. Petitioner also
requested verification from the Secretary that all applicable
laws and administrative procedures were followed with regard to
the assessment and collection of the tax liabilities in question.
E. The Appeals Office Hearing
By letter dated May 30, 2001, Appeals Officer Richard J.
Sigler (the Appeals officer) acknowledged receipt of petitioner’s
request for an administrative hearing. The Appeals officer then
went on to state, in part, as follows:
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