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Sell Under Deed of Trust. Petitioner did not inform the IRS of
the default or the scheduling of the foreclosure sale.
On February 18, 2000, the District Director in Seattle,
Pace’s superior, denied petitioner’s administrative claim for
damages. Petitioner engaged an attorney, Richard R. Sayers
(Sayers), to file a lawsuit in the United States District Court
for the Western District of Virginia, captioned Logical
Marketing, Inc. and Fletcher H. Hyler, III v. United States,
Civil Action No. 7:00295, in which petitioner sought damages for
IRS collection activities. Petitioner did not authorize Sayers
to represent petitioner before the IRS, and the lawsuit did not
seek to enjoin further efforts to collect petitioner’s tax
liabilities.
Collection Activities
Petitioner’s collection case was transferred from Virginia
to California and assigned to Revenue Officer David Rosado
(Rosado) in Redwood City, California. Rosado obtained
petitioner’s Portola Valley address from the IRS computer system,
which had been updated during the 12th week of the year 2000. At
petitioner’s behest, Rosado spoke to Stone on April 17, 2000, and
informed her that he was considering filing a notice of Federal
tax lien. Around this time, Stone received transcripts for the
years 1993, 1995, and 1997 for petitioner’s individual accounts.
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