Gregory L. Shireman - Page 4

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               Penalties were not assessed since the taxpayer was fully               
               cooperative and wants to eventually file an Offer and                  
               Compromise with Collection.                                            
               On July 24, 2000, respondent assessed tax liabilities,                 
          including additions to tax and interest, against petitioner in              
          the amounts of $861 and $6,995 for 1996 and 1997, respectively.             
          Respondent sent petitioner a Final Notice--Notice of Intent to              
          Levy and Notice of Your Right to a Hearing (Final Notice) for               
          1996 and 1997, on November 10, 2000.                                        
               On December 8, 2000, respondent received from petitioner a             
          Form 12153, Request for Collection Due Process Hearing.  In the             
          Form 12153 petitioner argued that “The numbers are all wrong, you           
          owe me a refund.”  Petitioner attached to the Form 12153 a 3-page           
          statement that contained tax-protester arguments.                           
               In October 2001, petitioner mailed a document entitled                 
          “Notice of Revocation of Signatures and Affidavit in Support                
          Thereof” to Treasury Secretary Paul O’Neill, IRS Commissioner               
          Charles Rossotti, and Attorney General John Ashcroft.  Petitioner           
          also mailed a letter entitled “Request for Status Determination”            
          to IRS Commissioner Charles Rossotti.  Both of these documents              
          contained tax-protester arguments.                                          
               Prior to the section 6330 hearing (hearing), respondent sent           
          petitioner transcripts of account for 1996 and 1997 at                      
          petitioner’s request.                                                       







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