- 2 - 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.” 1(...continued) references are to the Tax Court Rules of Practice and Procedure. This case was assigned pursuant to sec. 7443A(b)(4).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011