Wesley Sherwood - Page 8

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          under section 6702 for 1997-2001.  A Notice of Federal Tax Lien             
          was recorded in Salt Lake County, Utah.                                     
               On April 22, 2004, petitioner requested a hearing under                
          section 6330.  In the hearing request, petitioner contended:                
          (1) No lien may be imposed because no valid assessment was made;            
          (2) he did not receive a statutory notice and demand as required;           
          (3) the Appeals officer must, but did not, give him the Treasury            
          directive or regulation that identifies the statutory notice and            
          demand for payment; (4) he may challenge the underlying tax                 
          liabilities for 1998, 2001, and 2002, because he did not receive            
          a valid notice of deficiency for any of those years; (5) he is              
          entitled to, but did not, receive a copy of Form 23C; (6)                   
          respondent must prove that respondent mailed a notice of                    
          deficiency to him for each year in issue; and (7) the Appeals               
          officer must have at the hearing verification signed by the                 
          Secretary showing that the requirements of any applicable law or            
          administrative procedure have been met.                                     
               Appeals Officer Bruce Skidmore (Skidmore) was assigned to              
          petitioner’s case.  On June 18, 2004, Skidmore obtained computer            
          transcripts (transcripts) of petitioner’s accounts.  In a letter            
          to petitioner dated August 30, 2004, Skidmore said:  (1) He had             
          received petitioner’s request for a hearing; (2) the issues that            
          petitioner had raised in his request for a hearing were                     
          frivolous, and he might be subject to sanctions; (3) petitioner             






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