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REQUIRES you to have “verification from the Secretary
(or someone with delegated authority from him) that the
requirements of any applicable law or administrative
procedures have been met.” So unless you have, at the
very least, that document, you should not even schedule
a Due Process Hearing. * * * [Reproduced literally;
fn. ref. omitted.]
On November 16, 2002, petitioners sent a letter to “Internal
Revenue Service Appeals Office Supervisor”. In that letter,
petitioners stated in pertinent part:
This is to indicate irregularities in our requested Due
Process Hearing. According to title 26 sections 6320
and 6330 only a single year is at issue for each
hearing/appeal. Yet we are confronted with a partial
(prejudiced) appeals officer for the following reasons:
1. Multiple years of [sic] combined into a
single session, we are only allotted one
hearing/appeal per year in question.
2. The hearing/appeals officer is making demands
outside of sections 6320 and 6330 regarding
“filings must be current”. Which is
blatantly incorrect and harassing.
On November 20, 2002, respondent’s settlement officer held
an Appeals Office hearing with petitioners regarding the
respective notices of intent to levy with respect to their
taxable year 1996 and their taxable years 1997 and 1999. James
Cain accompanied petitioners to the Appeals Office hearing. The
settlement officer did not allow petitioners to make an audio
recording of the Appeals Office hearing.
On November 26, 2002, the settlement officer sent a letter
to petitioners (settlement officer’s November 26, 2002 letter)
with respect to their taxable years 1996, 1997, and 1999. That
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