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respondent’s Appeals Office (Appeals Office). In that form,
petitioner stated that he intended to make an audio recording of
his Appeals Office hearing. Petitioner attached, inter alia, a
document to Form 12153 (petitioner’s attachment to Form 12153)
that contained statements, contentions, arguments, and requests
that the Court finds to be frivolous and/or groundless.3
On September 12, 2002, respondent’s Appeals officer (Appeals
officer) sent petitioner a letter (Appeals officer’s September
12, 2002 letter). That letter stated in pertinent part:
I have scheduled the hearing you requested on this case
for the date and time shown above [October 3, 2002].
* * *
* * * * * * *
As a final note, you should be aware that for many
years the policy in Appeals was to allow tape or steno-
graphic recordings of Appeals hearings. Effective May
2, 2002, that policy changed. Such recordings are no
longer allowed.
On September 16, 2002, in response to the Appeals officer’s
September 12, 2002 letter, petitioner sent the Appeals officer a
letter. That letter stated in pertinent part:
Thank you for scheduling my Collections Due Process
Hearing. Your letter states that you will not allow an
audio or stenographic recording of the hearing. I must
ask you to cite your legal authority for not allowing
3Petitioner’s attachment to Form 12153 contained statements,
contentions, arguments, and requests that are very 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., Flathers v. Commissioner, T.C. Memo. 2003-60.
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Last modified: May 25, 2011