Leonard O. Parker, Jr. - Page 9

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          1(d)(2), Q&A-D7, Proced. & Admin. Regs., which provides that, if            
          a taxpayer receives notice that a lien or levy has been filed and           
          requests a hearing at respondent’s Appeals Office, the taxpayer             
          must be offered an opportunity for a hearing at the Appeals                 
          Office closest to the taxpayer’s residence.  See Katz v.                    
          Commissioner, 115 T.C. at 335-336; sec. 301.6320-1(d)(2), Q&A-D7,           
          Proced. & Admin. Regs.                                                      
               We conclude that petitioner requested a hearing by filing              
          Form 12153.  Respondent was required to provide him with an                 
          opportunity for a hearing at the Appeals Office closest to his              
          residence.  Katz v. Commissioner, supra; sec. 301.6320-1(d)(2),             
          Q&A-D7, Proced. & Admin. Regs.5                                             
          3.   Whether Petitioner Was Provided an Opportunity for a Hearing           
               at the Appeals Office Closest to His Residence                         
               Petitioner lived in New Orleans when he requested a hearing            
          under section 6320(b).  Respondent had an Appeals Office in New             
          Orleans at all times relevant to this case.  Respondent did not             




               4(...continued)                                                        
               representative, or some combination thereof. * * *                     
               5  Sec. 301.6320-1(d)(2), Q&A-D7, Proced. & Admin. Regs.,              
          provides:                                                                   
               Q-D7.  If a taxpayer wants a face-to-face CDP hearing, where           
          will it be held?                                                            
               A-D7.  The taxpayer must be offered an opportunity for a               
          hearing at the Appeals Office closest to taxpayer’s residence * * *         





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