James Vernon Williams - Page 5

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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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