Jerry D. Criner - Page 10

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          2002, letter, Mr. Penny noted that, based on his review of                  
          petitioner’s file, it appeared that all legal and administrative            
          procedures were met by respondent in filing the NFTL against                
          Alice Criner as nominee of petitioner.                                      
               On February 25, 2002, petitioner sent a letter to Mr. Penny            
          expressing concern that Mr. Penny had already come to a                     
          conclusion regarding the validity of the nominee NFTL without               
          “seeing, hearing or reviewing” petitioner’s proof that he did not           
          own the Claremore property.  Petitioner also expressed doubt that           
          a person employed by the Internal Revenue Service (IRS) or any              
          other branch of the Federal Government could review the evidence            
          and reach a fair and impartial ruling.  Petitioner also advised             
          Mr. Penny that he wanted to record the hearing, and he inquired             
          as to whether petitioner and his sister and up to 30 witnesses              
          would be reimbursed for the expense of attending the hearing.               
          Petitioner enclosed with the letter Form 2848, Power of Attorney            
          and Declaration of Representative, designating his sister,                  
          Jeannie McLelland, as his representative.                                   
               On March 7, 2002, Mr. Penny sent a letter to petitioner                
          informing him that the hearing had been scheduled for March 22,             
          2002, and that, in accordance with petitioner’s request, the                
          hearing would be recorded but at no cost to the Government.  The            
          letter also stated that, because the hearing was petitioner’s               
          hearing, witnesses would not be allowed to speak during the                 






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