- 3 -
On the same day, petitioner requested the referenced hearing
before the Internal Revenue Service Office of Appeals (Appeals).
Petitioner stated in his request that “I relied on the advice of
a tax return professional who had given me wrong information. I
do not owe the taxes which are now being billed to me.”
Appeals assigned petitioner’s request for a hearing to
Settlement Officer Roger Cable, an Appeals officer, and Mr. Cable
sent the case to Michael Generazio, a revenue agent in the Holly
Hill examination office, for the purpose of holding the hearing.1
Mr. Generazio held the hearing with petitioner in Holly Hill; as
respondent’s counsel explained at trial, “there wasn’t an appeals
officer there that could meet with Petitioner for the due process
matter, but –- so he was referred to an examiner there, who he
did meet with.” Following the hearing, Mr. Cable telephoned
petitioner to notify him that Mr. Generazio had concluded that
petitioner’s Federal income tax liabilities (overpayments) for
1995, 1996, and 1997 were:
Year Liability/(overpayments)
1995 1($129.74)
1996 10,525.56
1997 (1,973.66)
8,422.16
1 This amount was primarily (if not entirely)
attributable to interest payable by petitioner with
respect to that year’s taxes.
1 The revenue agent who recommended the levy was also
assigned to respondent’s Holly Hill examination office.
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Last modified: May 25, 2011