Robert Newstat - Page 20

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          addition, with regard to his desire to submit information in                
          person, petitioner had been unable to attend any of the                     
          previously proposed conferences and at no time communicated to              
          Ms. Carter a readiness or willingness to meet after the June 26,            
          2002, date.  Moreover, the above-quoted regulations confirm that            
          a conference between an Appeals officer and a taxpayer’s                    
          representative, not the taxpayer himself, may fulfill the                   
          statutory directive for a hearing.                                          
               Hence, at the time respondent issued the notice of                     
          determination, Ms. Carter had addressed in writing the sole                 
          statute of limitations issue raised by petitioner for 1985 in his           
          Form 1215312 and had held a face-to-face conference with                    
          petitioner’s representative, the consequences of which Mr. Lynch            
          clearly understood and had communicated to petitioner.  In these            
          circumstances, the Court is satisfied that, with respect to 1985,           
          petitioner was offered and received a full and fair hearing which           
          complied with the requirements of section 6330.                             
                    2.  Review of Underlying Liabilities                              
               As previously indicated, the petition filed in this case               
          focused solely on the contention that petitioner had not been               
          afforded a proper hearing for purposes of section 6330.                     


               11(...continued)                                                       
          shoulder their burden to pay timely.                                        
               12 See supra note 9.                                                   





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