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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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