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income taxes, how can he approve an IRS lien on our
property in connection with a tax the payment for which
he can not find shown in any law?
* * * * * * *
8) We maintain that there is no law that
authorizes the IRS to claim that we owe more
in income taxes * * * than the “zeros” we
reported on our income tax returns for those
years [1996, 1997, and 1999].
* * * Section 6201(a)(2)(A) further provides that
with respect to taxes “payable by stamp,” the Secretary
is authorized “to estimate the amount of tax which has
been omitted to be paid” by stamp. However, we cannot
find any provision in Code Section 6201 or any other
Code Section that authorizes the Secretary (let alone
the IRS) to similarly “estimate the amount of tax”
which we allegedly omitted from our 1996[, 1997, and
1999] tax returns. Therefore it is our contention that
no law authorizes the Secretary (let alone any IRS
agent) to determine that we owe more in income taxes
than the “zeros” we reported on our 1996[, 1997, and
1999] income tax returns. * * *
* * * * * * *
This is also to remind you that I will be tape
recording the CDP hearing and I will have a court
reporter present. I will also have a witness present.
[Reproduced literally; fn. refs. omitted.]
On October 21, 2002, the settlement officer sent a letter to
petitioners with respect to their taxable years 1996, 1997, and
1999. That letter stated in pertinent part:
Your Collection Due process appeal request has been
assigned to me for consideration.
I will contact you as soon as I am able to review your
file and determine if we can resolve your case by
correspondence or phone in lieu of a personal
conference. If a personal conference is needed, I will
schedule a meeting with you or your representative.
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