Steven John Rennie - Page 5




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          Apparently, petitioner argued that the Secretary must personally            
          meet the verification requirement.  Petitioner also contended               
          that, although he is required to comply with the statutes and               
          regulations, he does not have to comply with caselaw.  Petitioner           
          admitted that he did not read any of the cases interpreting the             
          statutes and regulations.  Petitioner also argued that respondent           
          had not shown him the particular laws that expressly state that             
          income is taxable to individuals or that define the term                    
          “income”.                                                                   
               There was also a discussion of the statutory notice of                 
          deficiency.  Petitioner admitted that he had received the                   
          document that the Appeals officer described as the Statutory                
          Notice of Deficiency, but petitioner contended that it was not a            
          “legal notice of deficiency” because it was not signed by the               
          Secretary or an authorized designee.  Petitioner also made the              
          same argument with respect to whether the notice for payment was            
          a proper notice and demand for payment.                                     
               Accordingly, although petitioner received all of the                   
          documents that respondent is required to provide before pursuing            
          collection, petitioner generally contended that the documents are           
          defective for lack of the Secretary’s signature or that they are            
          on the wrong form.  In that regard, petitioner argued that                  
          respondent was required to use a particular form in order to                
          satisfy the notice and demand requirement of the statute.                   






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