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On August 8, 2000, respondent’s Appeals officer (Appeals
officer) sent petitioner a letter (August 8, 2000 letter) indi-
cating that respondent had received Form 12153 from petitioner
and requesting that petitioner provide the Appeals officer with
the following on or before August 28, 2000:
it is necessary to determine the facts of your case so
that you have an opportunity to provide arguments
regarding those facts.
The focus of your arguments should be other than moral,
religious, political or constitutional issues.
Please provide your objections to the factual issues of
this case so that full consideration of your request
can be conducted.
On August 25, 2000, in response to the Appeals officer’s August
8, 2000 letter, respondent received from petitioner a copy of
petitioner’s attachment to Form 12153.
On August 8, 2001, the Appeals officer offered petitioner a
face-to-face Appeals Office hearing and provided him with a
literal transcript of his accounts with respect to each of his
taxable years 1994, 1995, and 1996. On August 23, 2001, the
Appeals officer held an Appeals Office hearing with petitioner.
At that hearing, petitioner made the same statements and requests
3(...continued)
contentions, arguments, and requests that are similar to the
statements, contentions, arguments, and requests contained in the
attachments to Forms 12153 filed with the Internal Revenue
Service by certain other taxpayers with cases in the Court. See,
e.g., Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v.
Commissioner, T.C. Memo. 2003-45.
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Last modified: May 25, 2011