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Thereafter, on March 1, 2004, respondent issued to
petitioner a Final Notice - Notice of Intent to Levy and Notice
of Your Right to a Hearing with respect to the years in issue.
In response, petitioner timely submitted to respondent a Form
12153, Request for Collection Due Process Hearing, which stated
that his disagreement with the levy was as follows: “ASSESSMENT
INVALID”. The Appeals Office settlement officer assigned to
petitioner’s case, J. Feist (Mr. Feist), wrote to petitioner on
June 15, 2004, to notify him of his assignment, conference
procedural practices, and the scheduled hearing date of July 2,
2004. Petitioner subsequently sent to Mr. Feist a letter dated
June 27, 2004, that requested the hearing date be rescheduled for
the middle of July and provided notice of his intention to audio
record the hearing.
The hearing was conducted via telephone on July 12, 2004.
Shortly after the hearing began, petitioner informed Mr. Feist
that he was recording the hearing. Mr. Feist explained to
petitioner that only face-to-face hearings may be recorded. He
also advised that petitioner did not qualify for a face-to-face
hearing as petitioner had only raised frivolous arguments. Mr.
Feist ended the hearing when petitioner refused to cease
recording and failed to raise any nonfrivolous relevant issues.
Respondent then issued to petitioner the above-mentioned
Notice of Determination Concerning Collection Action(s) Under
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Last modified: May 25, 2011