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Petitioner and the Appeals officer held two telephone
conversations on July 2, 2001, and October 23, 2001. After the
telephone conversations petitioner submitted a 50-page document
that contained tax-protester arguments.
A face-to-face meeting was held on December 19, 2001, at
which petitioner told the Appeals officer that he believed he had
been coerced into signing the Form 4549-CG. Petitioner was
allowed to review the Appeals officer’s administrative file and
was provided copies of documents he requested.
On January 14, 2002, petitioner submitted a 37-page written
document to the Appeals officer. The document contained tax-
protester arguments.
In the December 12, 2002, Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 for 1996 and
1997, the Appeals officer found there to be “no credible evidence
that any Internal Revenue Service employee procured the
taxpayer’s waiver of the restrictions on assessment through
duress, coercion, fraud, or misrepresentation.” The Appeals
officer also determined that collection may proceed for 1996 and
1997. In making the determination, the Appeals officer relied on
transcripts of petitioner’s account to verify the assessments.
On January 10, 2003, petitioner filed a petition for
judicial review of respondent’s determination with the Court.
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Last modified: May 25, 2011