- 6 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011