Carol Lee Moore - Page 3




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          repeatedly proven that EIC, dependents and head of household are            
          valid claims.”  (Emphasis in original.)                                     
               On March 9, 2001, respondent sent petitioner a letter                  
          scheduling the hearing with an Appeals officer on March 20, 2001            
          in Syracuse, New York.  In response to petitioner’s request to              
          reschedule the hearing, the Appeals officer sent petitioner a               
          letter on March 16, 2001, rescheduling the hearing to March 22,             
          2001, in Syracuse, New York.  Petitioner did not appear at the              
          hearing.  On March 22, 2001, the Appeals officer sent petitioner            
          a letter notifying her that if she did not contact him within 14            
          days, he would close the file with respect to the hearing                   
          request.  On April 9, 2001, in response to a telephone message              
          left by petitioner, the Appeals officer left a telephone message            
          with petitioner requesting that she call him regarding                      
          rescheduling the hearing.  Petitioner did not return the                    
          telephone call.                                                             
               On May 9, 2001, respondent sent petitioner a notice of                 
          determination.  In the notice of determination, respondent                  
          stated:                                                                     
                    Appeals has determined that the notice of lien filed              
               for this tax period properly balances the need for efficient           
               collection of the tax with your concerns over the                      
               intrusiveness of the collection action.  You have not raised           
               an issue concerning the underlying liability that can be               
               considered in a due process hearing and have not made a                
               payment proposal.                                                      








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