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pertaining to, among other things, the underlying tax liability,
the assessment, the notice and demand for payment, and the
verification from the Secretary that the requirements of any
applicable law or procedure had been met. The attachments also
include the following statement: “This is also to remind you
that I will be tape recording the CDP hearing. I will also have
a court reporter.”
Settlement Officer Angela M. Carmouche (Ms. Carmouche), of
the IRS Office of Appeals in Phoenix, Arizona, sent petitioner a
letter dated June 1, 2003, scheduling a hearing for June 26,
2003. The letter briefly outlined the hearing process, advised
that audio or stenographic recording of hearings was not allowed,
and explained the circumstances in which challenges to the
underlying liability would be barred by section 6330(c)(2)(B).
The letter also warned petitioner with respect to frivolous
arguments and sanctions therefor, citing pertinent cases and
administrative materials. Ms. Carmouche enclosed with the letter
copies of Form 4340, Certificate of Assessments, Payments and
Other Specified Matters, for 1999; of Pierson v. Commissioner,
115 T.C. 576 (2000); and of Davis v. Commissioner, 115 T.C. 35
(2000).
At the request of petitioner, the hearing was subsequently
rescheduled for July 25, 2003, and a face-to-face conference
between petitioner and Ms. Carmouche was held on that date.
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