Scott William Katz - Page 6




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          letter, petitioner requested that the Appeals hearing “take place           
          in West Palm Beach, Florida since all of the witnesses live and             
          work in West Palm Beach, Florida.”                                          
               On June 7, 1999, after receiving the Appeals officer’s                 
          letter dated May 24, 1999, petitioner again transmitted a letter            
          to the Appeals officer requesting “that any and all hearings be             
          held in West Palm Beach, Florida.”  Petitioner further stated               
          that “all of my witnesses and people involved * * * [with regard            
          to] the 1990 [tax year] are in West Palm Beach, Florida.  In                
          short, I will not attend the conference you set up on 6/8/99.               
          * * *  Again, please reset the matter for a conference in West              
          Palm Beach, Florida.  I cannot appear with my witnesses almost an           
          hour away.”                                                                 
               On June 21, 1999, petitioner and the Appeals officer had a             
          telephone conversation in which they discussed petitioner’s 1990            
          tax year.  During the telephone conversation, the Appeals officer           
          informed petitioner that Appeals hearings were not available in             
          West Palm Beach, Florida, but rather were conducted in Sunrise,             
          Florida.  On June 23, 1999, the Appeals officer followed up the             
          telephone conversation with a letter in which he stated that he             
          saw “no basis for recommending abatement of the 1990 income tax             
          liability.”  The Appeals officer also informed petitioner that he           
          could (1) petition the Tax Court to review the lien filing                  
          following the issuance of a notice of determination by the                  






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