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tached a document to petitioner’s Form 12153. That attachment
stated in pertinent part:
1. Refer to the Tax Reformation Act of 1998.
2. I don’t agree for all the reasons Congress has
determined that I have this hearing.
3. Details will be both provided and disclosed at the
hearing.
4. I fully intend to cassette record the proceedings of
the hearing.
5. I request a face-to-face hearing.
In response to petitioner’s Form 12153, a settlement officer
with the Appeals Office (settlement officer) sent to petitioner a
letter dated October 7, 2005 (settlement officer’s October 7,
2005 letter). That letter stated in pertinent part:
Tax Period(s) Ended:
12/2001 & 2002
Date of Conference:
October 27, 2005
Time of Conference:
1:00 PM
* * * * * * *
We received your request for a Collection Due Process
(CDP) Hearing. While you do not specify the items that
you wish to address in a conference, the information
you provide leads me to believe that your CDP request
is intended to discuss 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.
Examples of arguments that are considered frivolous or
groundless are provided in “The Truth About Frivolous
Tax Arguments”, a copy of which is enclosed. Please
note that it is not a complete list of frivolous and
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