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held on June 28, 2002, and requested petitioner to confirm that
date by the end of April 2002. Because petitioner did not
respond to the March 21, March 29, and May 7 letters, the Appeals
officer stated in his June 7, 2002, letter that he would assume
that petitioner was forgoing the face-to-face hearing and advised
petitioner that he (the Appeals officer) could make a
determination to sustain the levy action because petitioner has
failed to set a time for a hearing. The Appeals officer also
informed petitioner that he had received a box of papers and a
video tape on May 31, 2002.3 On June 13, 2002, petitioner
finally responded to the June 7 letter and requested that the
hearing be postponed indefinitely or “at least into late July”.
Petitioner’s response stated that his wife had health problems.
The Appeals officer responded to that letter of petitioner
on July 3, 2002, enclosing additional MFTRA-X transcripts of
petitioner’s accounts. That letter stated:
We have spent time corresponding with discussions about
your underlying liability, but you are preclude [sic]
from raising such issues in this proceeding since you
have been properly given the right to dispute those
issues before. You have refused to acknowledge that
your income is subject to tax and refused to submit
information to change that tax liability.
You should concentrate your efforts in preparing and
filing proper returns for 1994 through current years so
3 The record does not reveal the contents of the box of
papers or the video tape.
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Last modified: May 25, 2011