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Request for a Collection Due Process Hearing; however, respondent
treated petitioner’s January 31, 2001, letter as the equivalent
of a Form 12153--i.e., as a request for a section 6330 hearing.
On February 26, 2001, respondent sent petitioner a letter
notifying him that his case had been assigned to an Appeals
officer.
On March 8, 2001, petitioner responded to respondent’s
February 26, 2001, letter with frivolous and groundless
arguments.
On April 2, 2002, Appeals Officer Donna Chilton invited
petitioner to attend a section 6330 hearing with her at 10 a.m.
on April 24, 2002, in Anchorage, Alaska.
On April 15, 2002, petitioner wrote to Ms. Chilton to advise
her that April 24, 2002, was not a convenient time and that he
was seeking an attorney to represent him. Petitioner requested
that the hearing be held during the week of May 19, 2002, as he
would be in Anchorage, Alaska, during that time. Ms. Chilton
rescheduled petitioner’s hearing, on the basis of his request,
for May 21, 2002.
On May 14, 2002, petitioner sent Ms. Chilton a letter in
lieu of a face-to-face hearing. Regarding 1994 and 1996,
petitioner argued that the assessments were barred by the period
of limitations. Regarding 1995 and 1997, petitioner claimed he
did not receive any “notices of assessment” for 1995 and 1997 and
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