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Petitioner and his wife did not file a petition with the
Court to redetermine the deficiency. Instead, petitioner mailed
a letter dated July 25, 2002, to the contact person named in the
notice of deficiency with copies to the Secretary of the
Treasury, the Commissioner of Internal Revenue, Senator Baucus,
Chairman of the Senate Finance Committee, Senator Conrad,
Chairman of the Tax and IRS Oversight Sub-Committee, and
Congressman Thomas, Chairman of the House Ways and Means
Committee, stating that he would not file a petition with the Tax
Court until it was established that respondent had the legal
authority to send the notice of deficiency in the first place.
Respondent assessed the tax, penalty, and interest on
November 18, 2002. On March 4, 2003, respondent mailed to
petitioner a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing. The final notice was not addressed to
petitioner’s wife, Sandra C. Krueger. On April 2, 2003,
petitioner timely filed a Form 12153, Request for a Collection
Due Process Hearing. Petitioner’s wife did not sign the Form
12153 and was not involved in the subsequent section 6330 hearing
or in the proceedings herein.
On April 8, 2004, respondent sent a letter to petitioner
advising him that a face-to-face conference would not be allowed
if petitioner continued making frivolous and groundless
arguments. The letter further stated: “If you wish to have a
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