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(request), dated July 2, 2005. On that form, petitioner repeated
his request for written confirmation that the information sought
by the IRS “never be used against * * * [him] as a link in the
chain of evidence in a criminal investigation or as evidence
against * * * [him] in a criminal prosecution”.
On July 14, 2005, the IRS sent a letter to petitioner,
informing him that his request for a CDP hearing had been
forwarded to Appeals for consideration. In a letter dated
September 12, 2005, petitioner was given the name of Settlement
Officer Genene Hopkins (Hopkins), as the person to contact with
any questions. On September 29, 2005, Hopkins sent to petitioner
a letter that informed him that the statements made in his
request are items that: “1. Courts have determined are frivolous
or groundless, or 2. Appeals does not consider. These are moral,
religious, political, constitutional, conscientious, or similar
grounds.” Also in this letter, Hopkins described what she must
consider during the hearing, stating:
Whether the IRS met all the requirements of any
applicable law or administrative procedure
Any relevant issues you wish to discuss. These can
include:
1. Collection alternatives to levy * * *.
2. Challenges to the appropriateness of
collection action. * * *
3. Spousal defenses, when applicable.
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