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collect petitioner’s outstanding tax liability by levy pursuant
to section 6330.
Background
At the time of filing the petition, petitioner resided in
Fremont, Ohio.
Petitioner filed a Federal income tax return for taxable
year 1998 showing an amount due. Respondent assessed the amount
due and sent petitioner notice and demand for payment. On
June 23, 2001, respondent sent petitioner a Letter 1058, Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing. The Letter 1058 shows an outstanding liability for
taxable year 1998 of $1,290.61.
On July 19, 2001, petitioner submitted a timely Form 12153,
Request for a Collection Due Process Hearing. The Form 12153 was
accompanied by a letter from petitioner’s representative, Jerry
A. Jewett (Mr. Jewett),2 containing frivolous arguments. On
March 21, 2002, respondent’s settlement officer held a face-to-
face hearing with petitioner and Mr. Jewett. Petitioner provided
a court reporter to transcribe the hearing.
2By order dated Feb. 20, 2004, Mr. Jewett was suspended from
practicing before this Court for 3 years for failure to comply
with the American Bar Association’s Model Rules of Professional
Conduct. Mr. Jewett subsequently withdrew as counsel of record
in the instant case.
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