Gregory R. Brown - Page 5

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               enforced collection action against my client can’t lawfully            
               proceed.  Okay.                                                        
          At the hearing, Mr. Jewett presented the Appeals Office with                
          various exhibits filled with basic tax-protester arguments.                 
               On April 10, 2002, a Notice of Determination Concerning                
          Collection Action(s) Under Section 6320/6330 was sent to                    
          petitioner.  The notice stated:                                             
                    During the March 28, 2002 office hearing, Mr. Jewett              
               and yourself were advised of the above limitations on issues           
               that could be raised or would be considered at the hearing.            
               You were advised of possible sanctions under IRC �6673 for             
               maintaining frivolous arguments.  You were advised Appeals             
               is relying on Form 4340 to verify that a valid assessment              
               was made, IRC �6303(a), Notice and Demand, and IRC �6331,              
               Notice of Intent to Levy were issued, and your own                     
               acknowledgment of receipt of the notice of deficiency to               
               limit challenges to the underlying liability.                          
                    Additional correspondence was received from Mr. Jewett            
               and yourself, which have been considered in the                        
               determination.  No other non-frivolous issues were raised.             
          As a result, respondent sustained the proposed levy with regard             
          to the 1998 tax liability.                                                  
               In the petition in this case, signed by Mr. Jewett,                    
          petitioner asserted:                                                        
               The decision of the hearing officer is incorrect for the               
               reasons set forth in the attached supplement to this                   
               Petition, in addition to the fact that the IRS has not                 
               complied with the applicable laws and administrative                   
               procedures, the collection procedures are inappropriate and            
               illegal, and Gregory R. Brown has no liability for the taxes           
               and penalties at issue.                                                
          Mr. Jewett attached to the petition a six-page supplement filled            
          with similar tax-protester arguments.  The same arguments were              






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