Christopher Kiley - Page 15

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               E.  Respondent’s Efforts To Schedule an Administrative                 
               By letter dated October 23, 2001, an Appeals officer in                
          respondent’s Appeals Office in Albuquerque, New Mexico, scheduled           
          an administrative hearing for petitioner on December 17, 2001, in           
          Las Vegas, Nevada, the location closest to petitioner’s residence           
          in Pahrump, Nevada, in respect of the 3 taxable years in issue.             
          The penultimate paragraph of the Appeals officer’s letter stated            
          as follows:                                                                 
               IF YOU FAIL TO APPEAR FOR THE HEARING: This will be                    
               your only opportunity for a face-to-face hearing.  If                  
               you cannot appear for the Hearing, I have scheduled a                  
               telephone Hearing for you on January 15, 2002 at 9:00                  
               A.M. (MST).  Please call me on the scheduled date and                  
               at the scheduled time if you cannot attend the face-to-                
               face hearing.  If I do not hear from you by the date                   
               scheduled for the telephone hearing, your hearing will                 
               consist of a review of your administrative file and all                
               correspondence provided by you.                                        
          The Appeals officer included with his October 23, 2001, letter              
          Form 4340, Certificate of Assessments, Payments and Other                   
          Specified Matters, for each of the 3 taxable years in issue.                
               Petitioner did not attend the December 17, 2001,                       
          administrative hearing in Las Vegas, Nevada, nor did petitioner             
          participate in a telephone conference on January 15, 2002.                  
               F.  Respondent’s Notice of Determination                               
               On February 14, 2002, respondent’s Appeals Office issued to            
          petitioner a Notice of Determination Concerning Collection                  
          Action(s) Under Section 6320 and/or 6330 with regard to his tax             

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