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Huss into signing the stipulated decision document. Petitioner
wrote, in part:
Before I even entered the hearing, Ms. Erin Hess
[sic] confronted my accountant, who had accompanied me
to explain what happened to the documents. She
aggressively dressed him down verbally and the
character of her accusations so intimidated him that he
turned on his heel and left the building, abandoning
me. I was then coerced into signing the decision
document by Ms. Hess, who demanded that I either sign
the document immediately or she would have me jailed on
the spot.
I never went before the Judge to argue my case and
defend myself as a result of the actions of Ms. Hess.
And it was not a matter of choice. I even tried to
leave the court building when faced with this illegal
and unconscionable onslaught, but Ms. Hess had me
brought back to her by two court security guards
against my wishes. There is no way I would have signed
that decision document any other way because I KNEW I
did not owe the money. And in spite of all the denials
of irresponsible behavior by IRS counsel and their
associates, I continue to be on the target of threats
and intimidation from the district counsel’s office
over this matter.
Petitioner’s letter was filed by the Court as petitioner’s
Motion on January 21, 2004.
Discussion
Under section 7481(b), a decision of the Court in a small
tax case becomes final 90 days after the decision is entered.
Rule 162 provides that a motion to vacate or revise a decision
shall be filed within 30 days after the decision has been entered
unless the Court shall otherwise permit.
As previously noted, the decision in this case was entered
on February 29, 2000. Petitioner did not file a motion to vacate
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