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all section references are to the Internal Revenue Code in effect
for the years in issue.
Petitioner resided in Robesonia, Pennsylvania, at the time
that his petition was filed. In response to a notice of intent
to levy for 1991 and 1992, petitioner requested a hearing under
section 6330.
On May 8, 2001, an Appeals officer sent to petitioner a
letter as follows:
I scheduled the conference you requested on this case
for * * * [June 13, 2001, 10 a.m.]. Please let me know
within 10 days from the date of this letter whether
this is convenient. If it is not, I will be glad to
arrange another time.
The conference will be informal. You may present
facts, arguments, and legal authority to support your
position. If you plan to introduce new evidence or
information, send it to me at least 10 days before the
conference. Statements of fact should be presented as
affidavits or signed under penalties of perjury.
You can authorize an attorney, certified public
accountant, or person enrolled to practice before the
Internal Revenue Service to represent you at the
conference. Your authorization should be made on a
Form 2848 (Power of Attorney and Declaration of
Representative), Form 8821 (Tax Information
Authorization and Declaration of Representative), or a
similar document.
I hope our conference will resolve your case. Call me
if you have any questions or need additional
information.
Petitioner did not appear at the time and place designated. The
Appeals officer reviewed transcripts of petitioner’s account and
determined that requirements of applicable laws and
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Last modified: May 25, 2011