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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 tax
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