- 4 - Petitioner’s February 4, 2004, letter indicated that his representative would be Wayne A. Paul, C.P.A. (Mr. Paul). Mr. Paul’s address and telephone number were included in the letter. On September 21, 2004, respondent’s settlement officer advised petitioner by letter that a telephone hearing was scheduled for October 19, 2004. In this letter, the settlement officer cautioned petitioner that the Appeals Office would not consider items that courts have determined are frivolous or groundless. Moreover, attached to the September 21 letter was a copy of this Court’s decision in Pierson v. Commissioner, 115 T.C. 576 (2000), IRS Publication 2105, “Why do I have to Pay Taxes?”, and also transcripts showing assessments, penalties, interest, and other items affecting petitioner’s account for the tax periods involved in the collection action. The settlement officer further advised petitioner that in order to qualify for a collection alternative, petitioner had to be in compliance with current tax obligations and that respondent’s records indicated that petitioner had not filed a return for any year from 1994 through 2003. The settlement officer requested additional information concerning petitioner’s financial situation and 5(...continued) that the case to which petitioner refers was dismissed by the District Court on Dec. 27, 2000, and a subsequent appeal in that case was dismissed on Aug. 5, 2005). Petitioner renewed his demand that respondent “produce the legal evidence of the law which gives you the statutory authority you rely upon.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007