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Appeals Office hearing with petitioner with respect to the notice
of tax lien. In connection with the telephonic Appeals Office
hearing, the settlement officer relied on transcripts of peti-
tioner’s accounts with respect to petitioner’s taxable years
1997, 1998, and 1999.
On a date not disclosed by the record, respondent sent to
petitioner by facsimile (respondent’s facsimile) pertinent
sections of the Code, the income tax regulations, and various
court cases which establish that petitioner is obligated to pay
tax, as well as any additions to tax and interest as provided by
law, for each of her taxable years 1997, 1998, and 1999.
On March 10, 2004, in response to respondent’s facsimile,
petitioner sent to respondent by facsimile a letter (petitioner’s
March 10, 2004 letter) that stated in pertinent part:
I specified on form 12153 that the notice of * * * lien
were Mathematically incorrect. And my question to you
was; Where is the statute and implementing regulation
that makes me liable for the penalty or tax? * * * I
have a copy of the IRC and the part of the Index, in
the front under the subject of “Liability for tax”
doesn’t even mention Subtitles A through C income
taxes. I have been looking at the laws and IRC Statues
and Regulations and they show I’m not liable, but
absolutely none that show that I am. I am not refusing
to pay I will gladly pay as you are requesting if you
would please show me the law that says I have “gross
income” form a taxable “situs” under 26 CFR � 1.861-
8(f) that is legally considered as “taxable income”.
Please just show me the amount of tax I owe in a way
that is consistent with Section 861 of the IRC and the
implementing regulation and statute. [Reproduced liter-
ally.]
On April 16, 2004, the Appeals Office issued to petitioner a
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