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because no delegation order exists which authorizes that person
to sign notices of deficiency for the Secretary of the Treasury.”
After petitioners defaulted on the March 30, 2000, notice of
deficiency, assessments of accuracy-related penalties and
additional income tax liabilities were made. Erroneously claimed
earned income credits were reversed on petitioners’ accounts for
the years in issue. A “Final Notice - Notice of Intent to Levy
and Notice of Your Right to a Hearing” was sent to petitioners on
December 18, 2000. A Notice of Federal Tax Lien was filed with
the Wyandot County Recorder on January 8, 2001, and a “Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320" was sent to petitioners on January 9, 2001.
Petitioners received the notices sent on December 18, 2000,
and January 9, 2001, marked them “Refused for Fraud”, and
returned them to the Internal Revenue Service (IRS), with
instructions that they be filed as a permanent part of
petitioners’ records. On January 11, 2001, petitioners filed a
Request for a Collection Due Process Hearing. In their request,
petitioners demanded a variety of forms, including a Form 23C, a
Form 17-A, a delegation order of the Revenue agent who sent the
notice of levy, and demanded “the law that makes us liable for
income taxes.” Among other things, petitioners demanded:
13. Provide the documents from the Internal Revenue
Code, the Code of Federal Regulations, United
States Statutes at Large, or Public Law that
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