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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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Last modified: May 25, 2011