- 3 - liability for 1997. On or about July 12, 2001, in response to the notice of intent to levy, petitioner filed Form 12153, Request for a Collection Due Process Hearing (Form 12153), and requested a hearing with respondent’s Appeals Office (Appeals Office). In Form 12153 that petitioner filed with respondent, petitioner stated only: “I believe it to be a big mistake. Need time to obtain documents and information from my IMF.” On October 16, 2001, the Appeals Office sent petitioner a letter notifying him that it had received petitioner’s Form 12153 and that it would be contacting him about an Appeals Office hearing. On March 14, 2002, respondent’s Appeals officer (Appeals officer) called petitioner to discuss petitioner’s case (March 14, 2002 telephone call). During that call, petitioner told the Appeals officer that he had retained JK Harris to represent him with respect to his Appeals Office hearing. The Appeals officer requested in the March 14, 2002 telephone call that petitioner submit to him Form 2848, Power of Attorney (Form 2848), authoriz- ing JK Harris to represent petitioner with respect to his Appeals Office hearing. The Appeals officer further indicated in the March 14, 2002 telephone call that, before the Appeals Office could consider any collection alternatives with respect to petitioner’s unpaid liability for 1997, petitioner must file taxPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011