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officer) informed petitioners that he had scheduled a hearing
(Appeals Office hearing) with them on November 27, 2002, with
respect to the notice of tax lien.
In response to the settlement officer’s October 31, 2002
letter, petitioners’ authorized representative sent a letter
dated November 19, 2002 (November 19, 2002 letter) to the settle-
ment officer. The November 19, 2002 letter stated in pertinent
part:
I am in receipt of your letters dated 10-31-02,
and copies of those letters are attached as part of
this letter.
Also enclosed is a copy of the August 8, 2002
letter I sent the IRS concerning the various issues
relating to the denial of my client’s right to record
the hearing, as authorized by 26 USC �7521(a) * * *.
* * * * * * *
In addition, in my August 8, 2002, letter, I
demanded that the IRS appeals officer conducting the
hearing and issuing the decision provide me with a copy
of his pocket commission and a copy of the delegation
of authority from the Secretary of the Treasury autho-
rizing him to conduct the hearing and issue the deci-
sion. You have not provided me with those documents.
* * * * * * *
In view of these facts, then, my clients have
authorized me to advise you that they will not attend
the “hearing” you propose to conduct on November 27,
2002 in Cincinnati, Ohio.
However, you are hereby instructed to consider, in
your deliberations concerning the issues raised by my
clients all of the papers which have been submitted to
date concerning these matters, including the August 8,
2002 letter, the February 25, 2002 letter which insti-
tuted the appeal, the June 17, 2002 letter, and the
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