- 6 - 23, 2002. He did not do so, nor did he attend the hearing on May 23, 2002. Respondent filed a report with the Court in which respondent reported that petitioner did not propose an alternate date for a hearing other than October 12, 2002, nor did he otherwise correspond with the Appeals officer. We ordered petitioner to respond to respondent’s report and to show cause why the circumstances reported by respondent do not provide a sufficient basis to enter a decision for respondent. Petitioner’s response consisted of copies of the order to show cause, sections 601.102 through 601.105, Statement of Procedural Rules, and an index from the Code of Federal Regulations. He affixed to the pages five self-sticking, removable notes containing the following statements: “Requested a postponement to later date and was denied. Michael Nestor”, “Enclosed is material I would use at a hearing”, “No substitute return was ever offered by IRS. Surprise, surprise”, “Still can’t find law that requires me to pay an income tax”, and “If you can find the law please mail it to me. Thank you”. OPINION A. Background Respondent made a determination under section 6330 for tax years 1990-97, and petitioner filed a timely petition for review. Thus, we have jurisdiction under section 6330(d)(1)(A) to review respondent’s determination to proceed with collection of incomePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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