Scott Patriot
Ashville, NC 28803-10116

January 31, 2008

J. Craig Young
IRS
320 Federal Place, Room 509
Greensboro, NC 27401

Re: Hickman V. Commissioner, Docket No 43xxx

Dear Mr. Young,

Under Tax Court Rule 91, we are required to advise the Court about all facts and documents which we would like the Court to see in order to resolve this dispute. We must agree which facts and documents are not is dispute, and submit them to the court as a “Stipulation of Facts.”

I am requesting the following information which may be submitted informally by mail:

1. Why do you believe that the IRS Appeals Division’s Notice of Determination, mailed to me on November 1, 2006, is correct and accurate?

2. Why did the IRS refuse my collection alternatives? What else must I do to have my in- person hearing as the law requires?

3. Why did the IRS deny me an in-person hearing? What is their legal basis for refusing me a hearing as the law requires?

4. What frivolous and groundless argument did I make in my real and final CDPH request? Please identify them preciously or exactly. Explain exactly why they are frivolous. Are they listed on the IRS publication on frivolous arguments?

5. Why did the IRS make false accusations against me? Why did they accuse me of frivolous and groundless positions in my real and final request? Is the IRS trying to intimidate me?

6. Did the Appeals receive my substitute CDPH request and my recall letter? Why did they ignore it?

7. Do you understand you also can be penalized under IRC §6673 for vexatious and harassment pleadings?

8. In addition, please provide the following documents and evidence:

a. All documents that the show the determinations made in the notice of determination are correct, accurate, and
b. all documents you intend to use at trial.
c. All documents that I submitted in this case the IRS considers frivolous and groundless

I should also explain the possible consequences of your not participating in meaningful trail preparation, and/or appearing for the trial. In either case, I would make a Motion to Dismiss for lack of prosecution and the Tax court may dismiss your case and enter a decision against you.

Yours,

Scott Patriot