Wesley Sherwood - Page 10

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          demands for payment; (5) documents showing that notices of                  
          deficiency were sent to petitioner; and (6) verification from the           
          Secretary that the requirements of any applicable law or                    
          administrative procedure have been met.                                     
               In a letter to petitioner dated September 10, 2004, Skidmore           
          said that he was no longer available for a telephone conference             
          on September 21, 2004, and that the Secretary need not personally           
          verify that requirements of any applicable law or administrative            
          procedure were met because the Secretary delegates that                     
          responsibility.                                                             
               In a letter to petitioner dated September 13, 2004,                    
          Skidmore said that there is evidence that petitioner had received           
          the notice of deficiency and notice of lien.  Skidmore also said            
          that petitioner challenged the underlying tax liabilities on the            
          grounds that he had not received a proper notice of deficiency              
          and that petitioner had requested but not received written                  
          verification.  Skidmore said petitioner had not raised any proper           
          issues.  Skidmore offered to speak to petitioner by telephone               
          about the case on September 27 or 28, 2004.  Skidmore asked                 
          petitioner to respond by 2:30 p.m. on September 28, 2004.                   
               On September 20, 2004, petitioner wrote Skidmore to say that           
          a telephone conference is not acceptable, and that respondent               
          must provide petitioner with:  (1) A notice of deficiency and               
          notice and demand for payment; (2) delegation orders from the               






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