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not justify any change in respondent’s proposed adjustments for
her 1994 tax year. Petitioner stamped that letter “REFUSED FOR
FRAUD F.R.C.P. 9(b)” and returned it to respondent with an
attachment in which she raised 33 frivolous questions purportedly
related to her income tax liability.
B. The Notice of Intent To Levy
On February 23, 2000, respondent issued to petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing
relating to petitioner’s 1993 and 1994 tax years.
On March 22, 2000, petitioner filed a Form 12153, Request
for a Collection Due Process Hearing for 1993 and 1994. In a
letter attached to her request for a hearing, petitioner asked
that the Appeals officer have at the hearing the Treasury
regulation that requires her to pay tax and the delegation of
authority to IRS agents to enforce payment.
Respondent’s Appeals Officer, Catherine L. Lacienski
(Lacienski), scheduled petitioner’s hearing for December 7, 2000.
Lacienski sent petitioner copies of certified transcripts of
account for petitioner’s 1993 and 1994 tax years.
Petitioner wrote to Lacienski and asked that her hearing be
rescheduled for December 18, 2000. In that letter petitioner
said that she had not received a valid notice of deficiency or
notice and demand for payment, and she requested the following to
be provided to her at the hearing: (1) The signed returns that
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Last modified: May 25, 2011