Terri Armstrong - Page 6




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               4. Information regarding any higher than normal or                     
                    unusual expenses.                                                 
               5. Information regarding the real property you own.                    
                    i.e. appraised value, purchase price, mortgage                    
                    holders, balance due, equity.                                     
               I have scheduled a telephone Appeals hearing for                       
               Wednesday, June 6, 2001, at 09:00 a.m.  Please let me                  
               know if you are unable to hold your hearing at this                    
               date and time. * * *                                                   
               *      *      *       *      *       *       *                         
               If you have any questions or concerns, please contact                  
               me at telephone number, * * *, or address, Internal                    
               Revenue Service-Appeals, * * *, Denver, Colorado,                      
               80204.                                                                 
               Petitioner did not respond to the May 17, 2001 letter and              
          did not provide the Appeals officer with the information re-                
          quested in that letter.  Nor did petitioner advise the Appeals              
          officer that she objected to the telephonic hearing scheduled on            
          June 6, 2001, and that she wanted a face-to-face hearing.                   
               On May 31, 2001, the Appeals officer unsuccessfully at-                
          tempted to contact petitioner by telephone in order to reschedule           
          petitioner’s telephonic hearing that had been scheduled for June            
          6, 2001.  When petitioner did not answer her telephone, the                 
          Appeals officer left a message on petitioner’s answering machine            
          informing her that he had rescheduled petitioner’s telephonic               
          hearing to June 7, 2001, at 9 a.m.                                          
               Although petitioner received the message that the Appeals              
          officer had left on her answering machine on May 31, 2001,                  
          petitioner did not contact him to object to the telephonic                  






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