Lance A. McLee - Page 3

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          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 tax            






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