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October 3, 2003. In the request, petitioner states: “IRS does
not follow procedures. I request a certificate of assessment for
the amount that IRS claims I owe.”
On three occasions, respondent sent petitioner letters
informing him that his arguments have previously been determined
to be frivolous.2 Respondent advised petitioner that he was not
entitled to a face-to-face hearing unless he informed respondent
of any specific and relevant issues he wished respondent to
consider. If petitioner did not raise any relevant issues,
respondent stated that the hearing would be conducted over the
telephone or through correspondence.
In response to the first two letters, petitioner sent
additional requests for a face-to-face hearing.3 Petitioner did
not raise any relevant issues, but instead informed respondent
that he would tape record the hearing and would be accompanied by
a court reporter and a witness. Petitioner also requested that
respondent bring several documents to the hearing, including a
summary record of assessment, the tax returns on which the
assessment was based, and the notice and demand for payment.
On September 27, 2004, respondent scheduled a telephone
conference with petitioner for October 20, 2004. Respondent
2 Respondent’s letters were dated May 12, June 7, and Sept.
27, 2004.
3 Petitioner’s requests were dated May 27 and June 18,
2004.
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