- 7 -
Internal Revenue Service has complied with code and procedural
requirements in collecting the tax.”
In the petition in this case, signed by Mr. Jewett,
petitioners again challenge the authority of the officers issuing
the notice of deficiency, the notice of intent to levy and the
notice of lien, and the procedures by which the Appeals officer
verified the validity of the assessment; claim that they were
entitled to challenge the underlying liabilities because they
received no valid notice of deficiency; and assert that no
provision of the Internal Revenue Code makes them liable for the
income tax and penalties determined in the statutory notice. The
same arguments were repeated in petitioners’ trial memorandum
signed by Mr. Jewett and filed with the Court.
On May 30, 2003, Mr. Jewett and counsel for respondent
placed a conference telephone call to the Court in one of the
essentially identical cases on the Cleveland, Ohio, June 2, 2003,
calendar in which Mr. Jewett represented taxpayers.1 The
conference telephone call concerned the desire of the taxpayers
in one of Mr. Jewett’s cases to withdraw him as counsel and to
work with the IRS in attempting to resolve their tax liability.
During the conference telephone call, the Court advised
1 Three of those cases were submitted fully stipulated and
are in the same posture as this case. James Benson and
Melanie A. Dunham, docket No. 7029-02L; Gregory R. Brown, docket
No. 8368-02L; Harold V. and Imogene N. Pahl, docket No.
11572-02L.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011