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those years.7
At the hearing, petitioner acknowledged receiving the
transcripts that the Appeals officer had previously mailed to
him. Nevertheless, petitioner alleged that those transcripts
were unreliable because they failed to reflect that notices of
deficiency for 1997 and 1998 had been sent to him. Petitioner
also complained that he was being denied the right to separate
hearings for each of the two taxable years in issue; he also
insisted on revisiting the audit phase of his case and
challenging the existence or amount of his underlying tax
liabilities. The Appeals officer explained that because
petitioner had actually received notices of deficiency for 1997
and 1998 but had not filed a petition for redetermination with
the Tax Court, petitioner was precluded from challenging the
existence or amount of his underlying tax liabilities for those
years at the hearing. The Appeals officer also explained that
his review of petitioner’s transcripts of account for 1997 and
1998 was sufficient to satisfy the verification requirement of
section 6330(c)(1) that all applicable laws and administrative
procedures had been followed in the assessment and collection
process. Ultimately, after repeatedly offering to consider any
collection alternatives that petitioner might care to offer, and
7 A literal transcript is a transcript in “plain English”
with a minimum amount of “computerese”.
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