- 15 - E. Respondent’s Efforts To Schedule an Administrative Hearing 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 taxPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011