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petitioner sent a telefax to the settlement officer indicating
that Mr. Paul would be in touch with the settlement officer.
When there was no further communication from petitioner or Mr.
Paul by November 18, the settlement officer prepared and mailed a
letter scheduling a face-to-face hearing for December 14, 2004,
and reserved a conference room for that purpose.
On December 9, 2004, the settlement officer received a
telefax from petitioner in which petitioner indicated that he
would like to again reschedule the hearing because Mr. Paul would
be out of town on the scheduled hearing date (December 14, 2004)
and had not had time to prepare for the hearing. Petitioner
continued to raise frivolous arguments with respect to his tax
liability.6 The settlement officer then telephoned Mr. Paul and
advised Mr. Paul that respondent was not willing to schedule a
hearing for a third time, and that the arguments that petitioner
proposed to raise at the hearing were frivolous. The settlement
officer then left a voice mail message for petitioner that the
December 14, 2004, hearing would not be rescheduled.
On December 14, 2004, petitioner and Mr. Paul initiated a
telephone call to the settlement officer in which they stated
6Petitioner challenged the signature of the IRS agent who
signed the notice of Federal tax lien on behalf of another agent.
Petitioner wrote that “I understand that Treasury Orders allow a
delegation of authority to only one agent and the agent given the
authority is not able to substitute that authority for someone
else.”
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Last modified: November 10, 2007