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I have reviewed the correspondence you attached to your
requests for the collection due process hearings and
would like to point out that the courts have previously
ruled against your arguments, and in some instances,
have imposed sanctions. I have verified the validity
of the assessments through the review of the complete
computer transcripts, the tax return files and related
workpapers. I have no further legal obligation to
consider any challenge to the validity of the assess-
ment in the absence of independent proof that the
assessment was defective in some manner. I am hopeful
that you wish to discuss legitimate issues and alterna-
tives for resolving your case at the upcoming hearing.
I will have the original tax return for 1997 and 1998
available for your review at the hearing * * *
On May 3, 2002, the settlement officer sent petitioner
another letter. That letter stated in pertinent part:
I am writing to you regarding the upcoming collection
due process hearing set for May 14, 2002 at 10:00 a.m.
at the Las Vegas Appeals Office.
There has been a recent change in the audio recording
or stenographic recording of hearings before Appeals.
This practice will no longer be permitted. Your corre-
spondence with the request for the collection due
process hearing does not state if you wish to record,
however, I wanted to make you aware of this change in
the event you had planned to record the hearing or hire
someone to stenographically record the hearing.
The recording of hearings has always been discretionary
for Appeals under IRC �7521. You may still have a
witness present at the hearing; however, this witness
may not represent you or negotiate for you.
Shortly before May 8, 2002, in response to the settlement
officer’s April 10, 2002 letter, petitioner sent the settlement
officer a letter (petitioner’s May 8, 2002 letter) indicating
that petitioner intended to attend the Appeals Office hearing
scheduled for May 14, 2002. That letter also contained state-
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Last modified: May 25, 2011