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Petitioner did not timely file a Federal income tax return
for 1996. On September 14, 1998, respondent prepared a
substitute for return, and 3 days later petitioner submitted a
return that was filed as an amended return. The return
petitioner submitted reported $5,805 of tax due, which respondent
assessed.
Petitioner timely filed 1997 and 1998 individual Federal
income tax returns, reporting tax due of $7,037 and $7,842,
respectively, which respondent assessed.
On September 21, 2000, petitioner filed amended returns for
1993, 1994, 1995, 1996, and 1997 reporting the tax due on each
amended return as zero. Respondent treated these amended returns
as claims for refund and denied them.
On April 9, 2001, respondent issued a Letter 1058, Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing, to petitioner for the unpaid balances of the
aforementioned assessments for the tax years 1992, 1993, 1994,
1995, 1996, 1997, and 1998. On May 1, 2001, petitioner submitted
to respondent a Form 12153, Request for a Collection Due Process
Hearing. In his request, petitioner advised that he would have a
stenographer present at the hearing.
By letter dated May 3, 2002, the Appeals officer advised
petitioner that neither stenographic nor audio recording of the
hearing would be permitted. A hearing was held on May 22, 2002,
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