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returns for his taxable years 1996, 1999, and 2000 (petitioner’s
unfiled returns) and provide the Appeals officer with copies of
such returns after filing them.
On March 14, 2002, the Appeals officer sent petitioner a
letter (March 14, 2002 letter) confirming the discussion that he
had had with petitioner during the March 14, 2002 telephone call.
In the March 14, 2002 letter, the Appeals officer asked peti-
tioner to answer the following questions:
1) What law or administrative procedure has the
Service not followed?
2) What IRS actions do you not agree with? Pro-
vide specific reasons and documentation why you do not
agree.
3) What specific alternatives are you proposing to
resolve the tax liabilities.
On April 2, 2002, the Appeals officer telephoned petitioner
(April 2, 2002 telephone call) because the Appeals officer had
not received petitioner’s Form 2848 authorizing JK Harris to
represent him. During the April 2, 2002 telephone call, peti-
tioner advised the Appeals officer that he would send that form
to the Appeals officer and that he would file petitioner’s
unfiled returns.
On April 11, 2002, the Appeals officer telephoned petitioner
(April 11, 2002 telephone call) but was unable to reach him.
The Appeals officer left petitioner a message indicating that he
had still not received petitioner’s Form 2848 authorizing JK
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Last modified: May 25, 2011