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contending that even if section 6330 did not entitle her to a
formal face-to-face hearing under the APA, that section entitled
her to an informal face-to-face hearing, and the Appeals officer
rejected her request to have such a hearing. We have found that
the Appeals officer scheduled a telephonic hearing with peti-
tioner on June 6, 2001,12 and rescheduled that telephonic hearing
to June 7, 2001. We have also found that petitioner never
advised the Appeals officer that she objected to the telephonic
hearing scheduled for June 6, 2001, or the telephonic hearing
rescheduled for June 7, 2001, or that she wanted a face-to-face
hearing. In fact, petitioner never responded to the various
letters sent to her by the IRS Appeals Office or the various
telephone messages left by the Appeals officer on her answering
machine. Although Mr. Armstrong telephoned the Appeals officer
on July 14, 2001, at a time when he was no longer married to
petitioner, and left a message on the Appeals officer’s answering
machine that petitioner and he would be filing an amended tax
return for each of the taxable years 1992 and 1995, Mr. Armstrong
did not indicate in that message that petitioner wanted to
schedule a face-to-face hearing with the Appeals officer. Nor
did Mr. Armstrong indicate that petitioner wanted to schedule any
12The record does not disclose why the Appeals officer
decided to schedule a telephonic hearing with petitioner. We
take judicial notice that the distance between Denver, Colorado,
where the Appeals officer was located, and Orem, Utah, where
petitioner resided, is approximately 500 miles.
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