- 4 - various documents including “verification from the Secretary that the requirements of applicable law or administrative procedure have been met”. Petitioner’s case was assigned to a settlement officer (the settlement officer) with respondent’s Appeals Office in New Haven, Connecticut. By correspondence dated December 22, 2002, petitioner notified respondent that she wanted to audio record her upcoming CDP hearing. By letter dated April 23, 2003, the settlement officer informed petitioner that she would not be allowed to make an audio or stenographic recording of her CDP hearing and warned petitioner that “sanctions can and have been imposed by the courts for frivolous arguments (Ref: Peirson v. Commissioner and Davis v. Commissioner)”. The settlement officer attached to the letter a copy of petitioner’s Form 4340, Certificate of Assessments, Payments, and Other Specified Matters, and informed petitioner that the other documents she requested could be obtained under the Freedom of Information Act, 5 U.S.C. sec. 552 (2000). The settlement officer asked petitioner to submit a Form 433-A, Collection Information Statement for Wage Earners and Self-Employed Individuals, for purposes of evaluating her financial condition and eligibility for collection alternatives. 4(...continued) of precedent; to do so might suggest that these arguments have some colorable merit.”)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011