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which respondent’s determination was based were documents sent by
petitioner’s companies to respondent. Accordingly, even if
petitioner were entitled to challenge the merits of the
underlying tax liability, respondent has provided information
upon which the liability is based, and petitioner has shown no
error in respondent’s determination.
Petitioner’s contention that respondent’s tax determination
is part of a Governmentwide conspiracy against him has not been
shown to be anything more than a figment of petitioner’s
imagination.
Petitioner, although invited on several occasions for a
face-to-face hearing or one by telephone, did not take advantage
of the offer. It is again noted that respondent’s failure to
answer petitioner’s FOIA request was due to a procedural
deficiency in petitioner’s request. More importantly,
respondent’s Appeals officer provided petitioner with available
information in response to the questions and inquiries raised by
petitioner in writing.
In view of the foregoing, it appears that there has been no
abuse of discretion and that there is no reason why respondent
may not proceed with the proposed collection activity.
Decision will be entered
for respondent.
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Last modified: May 25, 2011