Franklin A. Ogden - Page 2




                                        - 2 -                                         
          Background                                                                  
               On July 8, 1999, respondent mailed to petitioner a Final               
          Notice Of Intent to Levy and Notice of Your Right To A Hearing              
          requesting that petitioner pay his delinquent income taxes for              
          the taxable year 1984.  Petitioner responded by filing with the             
          Internal Revenue Service Office of Appeals (Appeals Office) a               
          request for an administrative hearing.                                      
               By letter dated January 31, 2000, Appeals Officer Jose                 
          Gonzales directed petitioner to contact him by February 14, 2000,           
          for the purpose of scheduling an administrative hearing.  On                
          February 7, 2000, Appeals Officer Gonzales received a letter from           
          Gary Arthur DeMott (Mr. DeMott), identified in the letter as                
          petitioner’s representative, stating that petitioner intended to            
          challenge his underlying tax liability for 1984.  By letter dated           
          February 14, 2000, Appeals Officer Gonzales informed petitioner             
          that he had received a letter from Mr. DeMott, that Mr. DeMott              
          was not duly authorized to represent petitioner, and that “If I             
          do not hear from you and you do not provide additional evidence             
          or make arrangements to pay the tax for 1984 before February 24,            
          2000, I will send you a determination letter providing your                 
          judicial rights.”                                                           




               1(...continued)                                                        
          references are to the Tax Court Rules of Practice and Procedure.            
          This case was assigned pursuant to sec. 7443A(b)(4).                        




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