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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.”)
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