-12-
In order to protect my rights in this matter, I
must be able to bring a stenographer to the meeting so
there is a third party, written record of the proceed-
ing. * * *
On December 18, 2003, the settlement officer held a hearing
with petitioner that the settlement officer audiotaped and that
petitioner’s stenographer recorded. During that hearing, the
settlement officer explained the collection process to peti-
tioner, and petitioner submitted to the settlement officer Form
433D, Installment Agreement.
On February 9, 2004, the Appeals Office issued to petitioner
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). The notice
of determination stated in pertinent part:
Summary of Determination
The taxpayer voluntarily entered into a streamline
installment agreement for $130.00/month payable on the
26th of each month. The taxpayer paid his first in-
stallment payment and also the one-time user fee of
$43.00. Enforced collection action will not occur
while this agreement is in place. * * *
An attachment to the notice of determination stated in
pertinent part:
SUMMARY AND RECOMMENDATION
* * * * * * *
The taxpayer’s attachment to Form 12153 states, in
summary, that: “1.) the Notices of Deficiency for 1996
and 1997 are facially void; 2.) there was a failure to
generate an assessment list for the assessments for
1996 and 1997; 3.) there was a failure of the Commis-
sioner to certify and transmit the assessment list for
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