- 21 - attorneys in the Office of Chief Counsel. We note first that the contacts here occurred after this case was docketed, putting them outside the purview of Rev. Proc. 2000-43, supra. Even if the proscriptions of Rev. Proc. 2000-43, supra, were applied, there is no evidence or reason to suspect that the Chief Counsel attorney assigned to petitioner's case advised the IRS employee who made the decision to issue the Final Notice of Intent to Levy to petitioner. We are also mindful that petitioner at no point raised an issue with the Appeals employees that required the exercise of significant judgment. Prior to trial, petitioner never identified the nature of any challenge he wished to make with respect the underlying liabilities, even though advised by Appeals that he was entitled to do so with respect to 1990 through 1993. He offered no specific collection alternative (or, as a single filer, any spousal defenses). Rather, he presented a myriad of procedural challenges, the resolution of which, in our view, did not require the exercise of significant independent judgment. To the extent the Forms 1040X submitted by petitioner, which were reviewed by the Appeals employees, might be considered evidence of the nature of his challenge to the underlying liabilities, they contained tax protester arguments that do not warrant serious consideration.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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