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Although the notices of deficiency explained petitioner’s
right to petition the Tax Court to contest the deficiency
determinations, petitioner chose not to do so. Rather, in
various letters to respondent in 1997 through 1999, petitioner
acknowledged receipt of the notices of deficiency and disputed
respondent’s authority to issue them.
C. Respondent’s Final Notice and Petitioner’s Response
After sending petitioner a number of notices of intent to
levy, on October 17, 2000, respondent sent petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing in
respect of the assessments of petitioner’s deficiencies and
additions to tax, plus interest, for tax years 1995, 1996, and
1997. By letter dated November 3, 2000, petitioner requested an
administrative hearing.
D. The Appeals Office Hearing
On November 1, 2001, petitioner attended an administrative
hearing in Akron, Ohio, before respondent’s Appeals officer.
According to a purported transcript of the hearing attached to
petitioner’s petition, petitioner declined to discuss meaningful
collection alternatives at the hearing.2 Rather, petitioner
2 Petitioner’s purported transcript of the Appeals Office
hearing reveals that the only “collection alternative” he was
willing to discuss was patently spurious:
Now, I’m proposing an alternative for payment and that
is let the record show that I’m providing the Internal
(continued...)
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