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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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