John N. Sweeney - Page 3

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          On April 19, 2005, petitioner sent respondent a Form 12153,                 
          Request for a Collection Due Process Hearing.                               
               Respondent’s Appeals officer reviewed petitioner’s                     
          correspondence and determined that all of petitioner’s                      
          contentions were frivolous.  On July 25, 2005, respondent’s                 
          Appeals officer sent petitioner a letter in which respondent                
          notified petitioner that respondent had received petitioner’s               
          request for a section 6330 hearing and scheduled a telephone                
          conference for August 17, 2005, at 3 p.m.  The letter advised               
          petitioner that the underlying liabilities could not be raised at           
          the hearing because petitioner had received statutory notices of            
          deficiency.2  Respondent’s letter also directed petitioner to an            
          Internal Revenue Service (IRS) publication, “The Truth About                
          Frivolous Tax Arguments”, available on the IRS’s Web site.                  
          Finally, the letter advised petitioner of this Court’s authority            
          to impose a sanction of up to $25,000 pursuant to section 6673.             
               Petitioner did not respond to this letter and failed to                
          participate in the scheduled phone conference.  On August 22,               
          2005, respondent sent petitioner a letter again requesting that             
          petitioner contact respondent and provide any additional                    



               2Petitioner denies receiving a statutory notice of                     
          deficiency.  However, this is only because petitioner claims to             
          have received “non-statutory” notices of deficiency.                        
          Accordingly, the fact of receipt is deemed conceded.                        





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