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administrative requirements had been met with respect to the
assessment of the 2000 deficiency.
Although petitioner made numerous frivolous and groundless
arguments,12 including arguments that he is not required to pay
income tax and that no law authorizes the Internal Revenue
Service to make substitute returns, and generally engaged in
irresponsible behavior during the section 6330 hearing process
and at trial, his conduct does not obviate the responsibility of
a hearing officer under section 6330(c)(1) to obtain verification
that the legal and administrative requirements for a proper
assessment and related collection activity have been met.
Because it is clear from the record that the hearing officer did
not obtain or receive verification that respondent had issued a
notice of deficiency for 2000 to petitioner, we must conclude
that the requirements of section 6330(c)(1) were not met and that
the Appeals Office’s conclusion to the contrary was erroneous.
See Freije v. Commissioner, supra at 36. Because it is clear
that the Appeals Office reached its conclusion regarding the
section 6330(c)(1) requirement without a sound basis for the
conclusion in either fact or law, we hold that the Appeals Office
12 Among his arguments, petitioner asserts that there is no
statutory authority for imposing liability in connection with the
income taxes at issue and that no statute requires him to pay the
taxes assessed.
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