- 10 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011