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Secretary delegated authority to various IRS directors and
employees involved in petitioner’s case.
Mr. Lawrence Phillips, the settlement officer assigned to
petitioner’s case, mailed petitioner a letter dated July 20,
2004, that advised petitioner on the procedures of a collection
hearing. The letter warned that “items that you mention in your
CDP 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.” Mr. Phillips further enclosed with the
letter copies of Forms 4340, Certificate of Assessments,
Payments, and Other Specified Matters, for 1999 and 2000.
The collection hearing was held via telephone on August 5,
2004. During the hearing petitioner again demanded documentation
and reiterated tax-protester rhetoric. Petitioner also
questioned Mr. Phillips as to why his hearing was being conducted
by a settlement officer and not an Appeals officer.
On August 18, 2004, respondent mailed to petitioner the
above-mentioned Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 for the 1999 and 2000
taxable years. Petitioner timely filed a petition with this
Court for redetermination of the collection action. Therein, in
addition to contentions akin to those set forth in his Form
12153, petitioner argued: (1) Notices of Deficiency that are
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Last modified: May 25, 2011