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the taxes, additions to tax, and interest for all 5 years on
March 19, 2001. Notices of balance due were sent to petitioner
on that date, as well as on April 23, 2001.
Subsequently, on September 16, 2002, respondent issued to
petitioner a Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing, with regard to the 1993 through 1997
years. Respondent on October 22, 2002, received from petitioner
a Form 12153, Request for a Collection Due Process Hearing,
setting forth his disagreement with the proposed collection
action, as follows:
(1) There was a failure to determine a deficiency; (2)
There was a failure to issue a Notice of Deficiency;
(3) Any Notice of Deficiency was void as it included
income subject to Final Partnership Administrative
Adjustments under TEFRA; (4) There was a failure to
generate an assessment list; (5) There was a failure of
the Commissioner to certify and transmit the assessment
list; (6) There was a failure to record the assessment;
(7) failure to provide record of assessment; and, (8)
failure to send Notice of Assessment.
By a letter dated January 29, 2003, the settlement officer
to whom petitioner’s case had been assigned scheduled a hearing
for February 19, 2003, in Phoenix, Arizona. The letter enclosed
copies of Forms 4340, Certificate of Assessments, Payments and
Other Specified Matters, for each of the years in issue.
Petitioner appeared for the scheduled conference on
February 19, 2003, accompanied by a stenographer and James
Chisholm, who was identified as a witness. The settlement
officer advised petitioner that recording and stenography were no
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