Robert E. Crandall - Page 5

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          copies of Pierson v. Commissioner, 115 T.C. 576 (2000), and other           
          cases highlighting the invalidity of his arguments.                         
               Petitioner’s petition disputing the notice of determination            
          was filed with the Court on May 20, 2003, and reflected an                  
          address in Las Vegas, Nevada.3  Petitioner’s complaints with                
          respect to the administrative proceedings included the following:           
          No legitimate hearing under section 6330 ever took place;                   
          petitioner was not permitted to record the scheduled hearing;               
          petitioner was denied the opportunity to raise issues he deemed             
          “relevant” (e.g., the “existence” of the underlying tax                     
          liability); and requested documentation had not been produced               
          (e.g., record of the assessments, statutory notice and demand for           
          payment, and verification from the Secretary that all applicable            
          requirements were met).  Petitioner’s prayer asked this Court to            
          declare invalid the April 23, 2003, determination; order the IRS            
          to suspend enforcement activity until a hearing is held; order              
          the IRS to hold a hearing and to produce all requested                      

               3 The record also contains a copy of a letter dated June 20,           
          2003, and addressed to the Appeals officer, disputing the notice            
          of determination.  The letter is from a Milton H. Baxley II                 
          alleging to hold a power of attorney to act on behalf of                    
          petitioner.  The letter focuses in particular on claimed                    
          violations of the verification requirements of sec. 6330 and                
          contains a so-called offer to pay in full the amount of any tax             
          “upon presentment of a verified bill signed under penalty of                
          perjury by a person who has first hand knowledge of the facts,              
          and that the alleged amount is due and owing by my client, and              
          that the amount is true, correct, complete and not misleading.”             

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