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On September 27, 2005, respondent’s Appeals Office sent a
letter to petitioner explaining that a face-to-face hearing would
not be granted because petitioner raised only frivolous or
groundless arguments. The Appeals Office scheduled a telephone
hearing for October 27, 2005, at 8:30 a.m. and instructed
petitioner to call the phone number provided in the letter at the
given time.
In a letter dated October 6, 2005, petitioner argued that he
never received a notice of deficiency for 1999 and disputed his
tax liability for that year, but he stated that he did not want a
hearing for 1990 through 1993. Petitioner also failed to call
the Appeals officer on the scheduled hearing date, and the
Appeals officer was unable to contact petitioner because
petitioner failed to provide his phone number.
On November 8, 2005, the Appeals officer issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330, in which the Appeals
officer sustained the proposed collection action for 1990, 1991,
1992, and 1993.
On December 6, 2005, petitioner mailed a letter to the Court
that was received and filed on December 12, 2005, as an imperfect
petition. The Court ordered petitioner to submit a proper
amended petition because his original imperfect petition did not
conform with the Rules. On February 6, 2006, the Court received
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Last modified: March 27, 2008