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Between January 24 and May 7, 2001, petitioner, petitioner's
spouse, and petitioner’s legal representative exchanged a number
of letters with respondent’s Appeals officer in which petitioner
explained that petitioner would only be satisfied if respondent
provided to petitioner not the above transcripts of account but
specifically “Forms 23C, Summary Record of Assessments” relating
to petitioner’s Federal income taxes for 1992 and 1993.
In his letters, respondent’s Appeals officer made it clear
that respondent was relying on the above referenced transcripts
of account, not “Forms 23C”, to verify the assessments that were
the bases for the lien filing, and that respondent was willing to
meet face-to-face with petitioner and petitioner’s spouse and
representative and to make available to petitioner additional
copies of those transcripts. Respondent’s letters also suggested
specific dates for a face-to-face meeting, but petitioner and
petitioner’s representative refused to meet with respondent’s
Appeals officer unless a commitment was made by the Appeals
officer to obtain and to have at the meeting a copy of
“Forms 23C” relating to petitioner’s 1992 and 1993 Federal income
taxes.
On May 17, 2001, respondent’s Appeals Office mailed to
petitioner’s representative a notice of determination in which it
was explained that the above lien filing made by respondent with
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Last modified: May 25, 2011