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noncompliance with filing requirements would render collection
alternatives unavailable; and pointed petitioner to Pierson v
Commissioner, 115 T.C. 576, 581 (2000), and other cases
establishing imposition of sanctions in analogous circumstances.
Ms. Petersen enclosed with the letter certified transcripts of
account and copies or summaries of the various cited cases.
Petitioner again responded with a lengthy letter dated June 2,
2003, in the same vein as his earlier submissions. As regards
the hearing, he stated: “I’ll be there @ 1:00pm with recorder
running and plan to bring a witness or two.”
Petitioner appeared for the scheduled hearing on June 4,
2003, but the hearing did not proceed when Ms. Petersen refused
to permit petitioner to record the meeting. On July 18, 2003,
respondent issued to petitioner the aforementioned Notice of
Determination Concerning Collection Action Under Section 6330,
sustaining the proposed levy action. An attachment to the notice
addressed the verification of legal and procedural requirements,
the issues raised by the taxpayer, and the balancing of efficient
collection and intrusiveness. According to the attachment,
petitioner “did not raise any non-frivolous arguments.”
Petitioner’s petition disputing the notice of determination
was filed with the Court on August 18, 2003, and reflected an
address in Pahrump, Nevada. Therein petitioner (1) claimed that
he was denied a hearing on account of the inability to record,
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