James Vernon Williams - Page 4

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          of, and requested that the Appeals officer have at the hearing              
          copies of documents pertaining to, among other things, the                  
          underlying tax liability, the assessment, the notice and demand             
          for payment, and the verification from the Secretary that the               
          requirements of any applicable law or procedure had been met.               
               Appeals Officer Julieanne M. Petersen (Ms. Petersen), of the           
          Internal Revenue Service (IRS) Office of Appeals in Las Vegas,              
          Nevada, sent petitioner a letter dated May 5, 2003, scheduling a            
          hearing for June 4, 2003.  The letter briefly outlined the                  
          hearing process, advised that audio or stenographic recording of            
          hearings was not allowed, and explained the opportunity to                  
          present and discuss “non-frivolous” material.  The letter also              
          warned petitioner as follows:  “The Courts have deemed the                  
          arguments that are contained in your previous correspondence with           
          the Internal Revenue Service frivolous.  They will not hear them            
          and neither will they be addressed at your Collection Due Process           
               Petitioner responded on May 16, 2003, with a 17-page letter            
          asserting his right to record the hearing, as well as reiterating           
          and expanding upon arguments advanced in his previous                       
          communications.  Ms. Petersen sent a follow-up letter dated May             
          30, 2003, in which she specifically addressed petitioner’s                  
          arguments; cited numerous cases contrary to the positions being             
          taken by petitioner; alerted petitioner that his present                    

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