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To reconstruct petitioner’s income, respondent’s revenue
agent sent letters to petitioner’s accounting clients and asked
them to provide copies of canceled checks written to petitioner.
The revenue agent also sent copies of those letters to
petitioner. Petitioner demanded that the revenue agent stop
contacting his clients. Petitioner contended that the requests
to his clients were an unconstitutional invasion of his privacy.
The revenue agent issued summonses to petitioner’s banks.
Petitioner wrote letters to the revenue agent stating that the
summonses were invalid for several reasons, including: (1)
Issuance of the summonses violated (a) the U.S. Constitution; (b)
the Internal Revenue Manual; and (c) the Internal Revenue Service
Restructuring and Reform Act of 1998 (RRA 1998); and (2) the
revenue agent failed to provide petitioner with (a) a Privacy Act
statement; (b) a certificate of service of summons; (c) proof of
delegation of authority; and (d) notice stating whether the
documents sought by the revenue agent were for a civil or
criminal investigation.
Respondent sent petitioner proposed adjustments to his
income tax for 1994-99, letters, notice of amounts due, and
statements of account. Those notices and statements showed
amounts respondent had concluded petitioner owed for 1994-99.
Petitioner stamped those letters, notices, and statements of
account “Refused for Fraud F.R.C.P. 9(b)” and returned them to
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