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determination should be declared invalid; (2) the Appeals officer
did not conduct a hearing that was in accord with the statute;
(3) petitioner was not provided with information and
documentation that he is entitled to as a matter of law; and (4)
the Appeals officer was not authorized to represent the Secretary
of the Treasury.
The specifics underlying these allegations/issues, as far as
the Court is able to follow petitioner’s logic and explanations,
are: (1) The Appeals officer wrongfully refused to allow
petitioner’s representative to represent his interests; (2) the
Appeals officer wrongfully refused petitioner a face-to-face
meeting; (3) the Appeals officer did not show petitioner a
delegation order from the Secretary of the Treasury entitling the
Appeals officer to act on the Secretary’s behalf; (4) the Appeals
officer did not show petitioner the underlying assessment
documents with respect to the Form 4340 provided to petitioner;
and (5) the Appeals officer did not provide petitioner with the
statute or law that would make petitioner subject to and/or
liable for Federal income tax.
These, in essence, are the matters raised by petitioner in
his pleadings and, accordingly, are the matters that we must
address. Lunsford v. Commissioner, 117 T.C. 183, 189 (2001);
Goza v. Commissioner, 114 T.C. 176 (2000).
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Last modified: November 10, 2007