Michael L. Widner - Page 5

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               an accurate record of the hearing to be made by me.  I                 
               received a copy of IRS Publication 1 (Your Rights as a                 
               taxpayer), which clearly states that I have a right to                 
               record such proceedings.                                               
               On October 3, 2002, the Appeals officer held an Appeals                
          Office hearing with petitioner with respect to the notice of                
          intent to levy.  Cheryl Flathers (Ms. Flathers) accompanied                 
          petitioner to that hearing.  Although petitioner and Ms. Flathers           
          both knew that the Appeals Office no longer allowed audio record-           
          ings of Appeals Office hearings, petitioner and/or Ms. Flathers             
          secretly made an audio recording of petitioner’s Appeals Office             
          hearing.4  At the Appeals Office hearing, the Appeals officer               
          gave petitioner Form 4340, Certificate of Assessments, Payments,            
          and Other Specified Matters (Form 4340), with respect to peti-              
          tioner’s taxable year 1998.                                                 
               On October 29, 2002, the Appeals Office issued to petitioner           
          a notice of determination concerning collection action(s) under             
          section 6320 and/or 6330 (notice of determination).  An attach-             
          ment to that notice stated in pertinent part:                               
               Verification of Legal and Procedural Requirements                      
               The requirements of all applicable laws and administra-                
               tive procedures have been met:                                         
                    The liabilities were assessed and notice and                      

               4Ms. Flathers, who is no stranger to respondent’s Appeals              
          Office or the Court, made a secret recording of her own hearing             
          that respondent’s Appeals Office held with her pursuant to secs.            
          6320(b) and 6330(b) on May 16, 2002.  Flathers v. Commissioner,             

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