Gerald L. and Jessica P. Frey - Page 24

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               makes arguments similar to those you have made about                   
               Delegation Orders, etc.  As you can see, the Court                     
               decides the case in favor of the Government.                           
               On December 10, 2002, in response to the settlement                    
          officer’s November 26, 2002 letter to petitioners, petitioners              
          sent a letter to the settlement officer (petitioners’ December              
          10, 2002 letter).  Petitioners’ December 10, 2002 letter stated             
          in pertinent part:                                                          
               In response to your letter of November 26, 2002, and                   
               based upon your invitation to do so, we raise these                    
               valid issues in regard to your statements and exhibits:                
                    1.   We did not raise any arguments based on                      
                         moral, religious, political, constitutional,                 
                         conscientious or similar grounds, so we will                 
                         not help you to pretend that we did.                         
                    2.   On the issue of impartiality, your letter of                 
                         November 26th proves that you are NOT                        
                         impartial to the proposed collection action:                 
                              a.) We did not raise any arguments                      
                                   whatsoever.  We asked for the                      
                                   documents that the laws describe,                  
                                   which must be present before a                     
                                   determination can be made by you to                
                                   proceed with collection by                         
                                   distraint.                                         
                         We cite as a valid issue:  The Statute, IR                   
                    Code 6330(c)(3) entitled “Basis for the                           
                    determination.  The determination by an appeals                   
                    officer under this subsection shall take into                     
                    consideration-A.) the verification presented under                
                    paragraph (1),; B.) the issues raised under                       
                    paragraph (2), which is “any relevant issue                       
                    relating to the unpaid tax or proposed levy”...                   
                              b.) You state * * * “Based upon a                       
                                   review of your case file, I find no                
                                   error in the part of the Service in                
                                   sending you the proper notices of                  





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