Rockie D. Elmore - Page 3

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               C.  The Appeals Office Hearing                                         
               On March 28, 2002, the Elmores attended an administrative              
          hearing conducted by Appeals Officer Concepcion Robles, whose               
          post of duty was San Antonio, Texas.  The administrative hearing            
          was held at the IRS Appeals Office in Corpus Christi, Texas, the            
          city in which the Elmores resided.                                          
               By Appeals Transmittal and Case Memo dated April 1, 2002,              
          Appeals Officer Robles recommended to his manager that the                  
          Appeals Office issue a notice of determination.  At that time,              
          the Appeals officer’s manager was Appeals Team Manager John                 
          LaCoke of the San Antonio Appeals Office (ATM LaCoke).2  However,           
          ATM LaCoke was out of the office from April 2 to 4, 2002.  In his           
          absence, ATM LaCoke designated Appeals Officer Glenn Pederson as            
          the acting team manager.  On April 3, 2002, Acting ATM Pederson             
          approved the recommendation of Appeals Officer Robles that the              
          Appeals Office issue a notice of determination.                             
               D.  Respondent’s Notice of Determination                               
               On April 11, 2002, the Appeals Office issued to petitioner a           
          Notice of Determination Concerning Collection Action(s) Under               


               2  An Appeals team manager (ATM) is a supervisory Appeals              
          officer who is responsible for managing and reviewing Appeals               
          officers within the jurisdiction of a particular Appeals Office.            
          An ATM’s duties include, inter alia, reviewing work for quality             
          and professional standards, approving recommendations by Appeals            
          officers who lack authority to take the recommended action                  
          themselves, and supervising the general work performance of                 
          Appeals officers.                                                           





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