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Background
On July 8, 1999, respondent mailed to petitioner a Final
Notice Of Intent to Levy and Notice of Your Right To A Hearing
requesting that petitioner pay his delinquent income taxes for
the taxable year 1984. Petitioner responded by filing with the
Internal Revenue Service Office of Appeals (Appeals Office) a
request for an administrative hearing.
By letter dated January 31, 2000, Appeals Officer Jose
Gonzales directed petitioner to contact him by February 14, 2000,
for the purpose of scheduling an administrative hearing. On
February 7, 2000, Appeals Officer Gonzales received a letter from
Gary Arthur DeMott (Mr. DeMott), identified in the letter as
petitioner’s representative, stating that petitioner intended to
challenge his underlying tax liability for 1984. By letter dated
February 14, 2000, Appeals Officer Gonzales informed petitioner
that he had received a letter from Mr. DeMott, that Mr. DeMott
was not duly authorized to represent petitioner, and that “If I
do not hear from you and you do not provide additional evidence
or make arrangements to pay the tax for 1984 before February 24,
2000, I will send you a determination letter providing your
judicial rights.”
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references are to the Tax Court Rules of Practice and Procedure.
This case was assigned pursuant to sec. 7443A(b)(4).
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Last modified: May 25, 2011