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could have a face-to-face hearing if, within 15 days, he
identified in writing relevant issues, such as appropriate
spousal defenses, challenges to the appropriateness of collection
actions or alternatives to collection; and (4) petitioner could
dispute the amount of his tax liabilities only if he did not
receive a notice of deficiency or otherwise have an opportunity
to dispute the liabilities. Skidmore offered to discuss the case
by telephone with petitioner at 10 a.m. on September 21, 2004, or
2 p.m. on September 28, 2004. On August 30, 2004, Skidmore
obtained more transcripts of petitioner’s accounts.
On September 8, 2004, petitioner wrote Skidmore to request a
face-to-face hearing. Petitioner said that he intended to raise
the following issues at the hearing: (1) He did not receive any
notices from the Secretary; (2) no lien may be imposed because
there were no statutory notices and demands for payment and no
valid assessments were made; (3) persons who signed notices
lacked proper delegation of authority; and (4) the Secretary did
not verify that requirements of any applicable law or
administrative procedure were met. In his September 8, 2004
letter, petitioner asked Skidmore for copies of: (1) Delegations
of authority signed by the Secretary authorizing appropriate
individuals to send deficiency notices; (2) records of assessment
from the office of the Secretary; (3) the Code section and
regulations that make petitioner liable for tax; (4) notices and
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