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number shown above. Please enclose a copy of this letter
with any written correspondence.
On April 15, 1999, Mr. Wilson held a telephone conference
with Mr. Tilley in response to the request for a collection
hearing. Both parties discussed the issues in the request. Mr.
Wilson observed that there were four basic issues in petitioners’
protest and went over those issues with Mr. Tilley at that time.
One issue discussed was a notice of intent to levy sent to Mrs.
Tilley for years not applicable to her. Mr. Wilson discovered
this had been corrected and that an appropriate notice of intent
to levy had been sent. Another issue discussed during the
telephone conference was the application of funds received by way
of lien discharges and Mr. Wilson determined the funds had been
properly applied. Mr. Tilley argued that he was entitled to
certain deductions and credits. Mr. Wilson offered to send Mr.
Tilley the transcripts of account. Mr. Wilson observed that the
Tax Court had decided petitioners’ 1991 and 1992 years on the
merits. As to 1994 and 1995, Mr. Wilson noted that Mr. Tilley,
who had not filed returns for those years, was sent notices of
deficiency but did not file a petition with this Court. The last
issue Mr. Tilley and Mr. Wilson discussed during the telephone
conference was that Mr. Tilley challenged the Federal income tax
laws as being unconstitutional because they were capitation
taxes. Mr. Wilson advised Mr. Tilley that it was not the
function of Appeals to decide such questions but that these were
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