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underlying tax liability for 1997, as well as allegations that
petitioner was never provided with a valid notice of deficiency
or notice and demand for payment and that the Appeals officer had
failed “to identify the statute that makes me ‘liable to pay’ the
taxes at issue”. Petitioner also requested verification from the
Secretary that all applicable laws and administrative procedures
were followed with regard to the assessment and collection of the
tax liability in question.
D. The Appeals Office Hearing
On July 26, 2001, petitioner attended an administrative
hearing in Las Vegas, Nevada conducted by Appeals Officer Douglas
DeSoto (the Appeals officer). Prior to the hearing, the Appeals
officer obtained and reviewed Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters, pertaining to
petitioner’s account for the taxable year 1997. At the hearing,
the Appeals officer provided petitioner with a copy of that
document, as well as copies of several court cases, including
Pierson v. Commissioner, 115 T.C. 576 (2000).
During the hearing, petitioner requested that the Appeals
officer identify the statutory provisions establishing
petitioner’s liability for Federal income tax and provide
verification that all applicable laws and administrative
procedures had been followed in the assessment and collection
process. Petitioner was informed that Form 4340 was sufficient
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