- 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 Next
Last modified: November 10, 2007