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prompted to explain his or her disagreement with respondent’s
proposed collection activity, petitioner wrote:
I do not owe the amount shown. I do have receipts to
substantiate my deductions. They are with the IRS
downtown Los Angeles branch. I need time to retrieve
them. Ms. Snoody [sic] (rev agt) is aware of this.
* * * I did not have the opportunity to dispute tax.
In response to petitioner’s request for a hearing, in a
letter dated April 15, 1999, addressed to petitioner at the
Diamond Bar address, an Appeals officer, who was unaware that
petitioner was incarcerated at the time, scheduled a hearing for
May 20, 1999. Petitioner apparently contacted the Appeals
officer by telephone and requested that the hearing be
rescheduled for another date. Petitioner did not notify the
Appeals officer that he was incarcerated; the Appeals officer was
aware that petitioner had been convicted of criminal tax offenses
but believed that petitioner’s incarceration had been deferred
pending appeal of his criminal conviction. The hearing was
rescheduled for June 17, 1999. Petitioner failed to attend the
June hearing because he was incarcerated.
In a Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated July 6, 1999, addressed to
petitioner at the Diamond Bar address, respondent determined to
proceed with the proposed collection activity because: (1) “All
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