Nicholas & Carrie Cozzens - Page 4

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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             
                    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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