Gerald L. and Jessica P. Frey - Page 20

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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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