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On April 26, 2000, respondent provided written notification
to petitioner’s representative that a telephone hearing was
scheduled for June 6, 2000, and enclosed copies of respondent’s
computer transcripts of account for each of the tax years at
issue. The Appeals officer relied upon the computer transcripts
of account (a.k.a. MEFTRA or MEFTRA-X) that were contained in the
administrative file as both proof that a valid assessment was
made and verification of petitioner’s liability.
At the time scheduled for the hearing, the Appeals officer
placed telephone calls to petitioner’s representative at two
different telephone numbers provided by the representative.
Petitioner’s representative was not available at either number.
The Appeals officer left messages at both numbers requesting that
petitioner’s representative contact the Appeals officer to
reschedule the hearing. Petitioner’s representative did not
return either message.
On June 14, 2000, respondent sent to petitioner a “NOTICE
OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION
6320 AND/OR 6330” (notice of determination). The notice of
determination states in pertinent part:
You allege the assessments and the
liabilities are invalid. Statutory Notice of
Deficiency (SND) were sent to you dated March
28, 1997 for the 1992 tax year, and October
24, 1997 for the 1993, 1994 and 1995 tax
years. There is no evidence that you
responded to the SNDs either by filing
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