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By letter dated April 8, 2005, respondent’s Appeals officer
informed petitioner that his arguments in his hearing request
were either frivolous or groundless or issues that the Office of
Appeals does not consider. The letter informed petitioner that
the Office of Appeals would not provide a face-to-face hearing to
discuss these issues. The letter offered petitioner the option
of a hearing by telephone or correspondence. In the alternative,
the letter suggested various legitimate issues that could be
discussed in a face-to-face conference and gave petitioner
another opportunity to describe the legitimate issues petitioner
would want to raise at a face-to-face conference. Petitioner
responded with three more letters, requesting additional
materials, including a copy of the Appeals officer’s oath of
office.
On June 3, 2005, the Appeals Office issued its notice of
determination, sustaining the tax lien. In an attachment to the
notice, the Appeals officer stated that she had verified the
proper assessment of petitioner’s liabilities by reviewing
respondent’s Integrated Data Retrieval System (IDRS) and also
verified that notice and demand for payment had been made.
On July 11, 2005, petitioner filed his petition. On October
18, 2006, respondent filed a motion for summary judgment and to
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Last modified: May 25, 2011