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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
hearing.”
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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Last modified: May 25, 2011