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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 income
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