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but afforded petitioner an opportunity within 15 days to submit
relevant issues justifying an in-person interview. Petitioner
did not respond with legitimate issues but apparently spoke with
Mr. Freitag on November 4, 2003, continuing to insist on his
right to a face-to-face hearing. He was not afforded such an in-
person interview; instead, a series of letters resulted in what
was essentially a hearing by correspondence.
Petitioner sent a letter dated November 10, 2003,
reiterating and expanding upon his demands for a face-to-face
hearing and extensive documentation. He further tendered various
arguments about not having any “Income” in the “Constitutional
sense” and not being taxable under the provisions of section 861.
Mr. Freitag then sent two followup letters, dated November 19
and 21, 2003, respectively.
In the first, Mr. Freitag discussed at length the substance
of his review of petitioner’s case. Mr. Freitag again emphasized
the need to raise relevant issues and petitioner’s failure to do
so, and he warned about the possibility of sanctions. Concerning
liability, the letter noted: “As you did not have a prior
opportunity to dispute the assessments, you were allowed to
challenge the amount or existence of the underlying liability at
a CDP hearing however [sic] you have neglected to point [sic] any
irregularities in the making of the assessment. Instead you have
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