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were held on May 16, 2002 * * *. The taxpayer was
advised prior to the hearing by letter that no audio
recording or stenographic recording of the hearing
would be permitted per a directive issued by the Acting
Chief of Appeals dated May 2, 2002.
Settlement Officer Rene Swall has had no prior involve-
ment with respect to these liabilities.
Issues Raised by the Taxpayer
The taxpayer checked both blocks on the Form 12153 and
states, “see attached letter”. Attached is a copy of
the Notice of Federal Tax Lien (NFTL), the Letter 3172,
and several pages of non-filer arguments. As part of
the taxpayer’s argument, she asks for verification from
the secretary, proof of the assessments, [and] a copy
of the statutory notice of deficiency. The taxpayer
further claims that there is no underlying statutory
liability in connection with the income taxes at issue,
that there is no statute requiring her to pay the taxes
at issue, and that no law authorizes the Service to
claim that she owes more income tax than the “zero”
reported on her return. In addition the taxpayer
states that she did not receive a notice and demand for
payment per IRC �6331.
Certified transcripts, Forms 4340, for both periods
were provided to the taxpayer prior to the hearing.
The taxpayer was advised by letter that these tran-
scripts meet the verification requirements under IRC
�6330(c)(1). * * *
At the hearing the taxpayer raised the issue of audio
recording and was advised again that the audio record-
ing would not be allowed. * * *
* * * * * * *
I attempted to review the Form 4340 transcripts and the
administrative file with the taxpayer, which included
the tax return filed and the statutory notice of defi-
ciency that was sent and received. The taxpayer stated
that what I provided her as evidence of the statutory
notice of deficiency was only a “letter”. The taxpayer
was advised that she could not raise the issue of the
underlying liability as she had received the statutory
notice of deficiency, and had in fact responded to it
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