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* * * * * * *
A statutory notice of deficiency was issued to
your last known address on November 17, 1999 for 1997
but you failed to act upon this statutory notice. You
failed to petition the United States Tax Court for
redetermination. Thus, under IRC �6330(c)(2)(B), you
are precluded from challenging the underlying liability
for 1997 because you had a previous opportunity to
dispute such liability.
* * * I have scheduled a telephonic conference for
Wednesday, December 20, 2000 at 1:00 p.m. MST. * * *
* * * * * * *
If you have any questions, you may contact me at
the telephone number shown above any time before your
scheduled hearing.
Petitioners did not respond to the Appeals officer’s Decem-
ber 7, 2000 letters. Nor did petitioners advise the Appeals
officer that they objected to the telephonic hearing scheduled on
December 20, 2000, and wanted a face-to-face hearing.
On December 20, 2000, the Appeals officer held a telephonic
Appeals Office hearing with Mr. Frank with respect to the notice
of intent to levy.5 Prior to the Appeals Office hearing, the
Appeals officer gave petitioners a literal transcript of account
(so-called MFTRAX) with respect to their taxable year 1997.
On February 13, 2001, the Appeals Office issued a notice of
determination concerning collection action(s) under section 6320
and/or 6330 (notice of determination) to Mr. Frank and a separate
5Ms. Frank did not participate in the telephonic Appeals
Office hearing held on Dec. 20, 2000.
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