Antonio L. and Ernestine Thomas - Page 12

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          payments that petitioners have made since the examination                   
          assessment have been accounted for, and the amount respondent               
          seeks to collect is correct.                                                
          Necessity of a Face-to-Face Meeting                                         
               Finally, petitioners contend that their right to a hearing             
          under section 6330(b) was compromised by the settlement officer’s           
          issuing the determination letter without conducting a face-to-              
          face meeting.  The parties have stipulated that a meeting                   
          scheduled for November 19, 2001, was canceled by petitioners by             
          telephone on November 14, 2001, because of the illness of their             
          representative.  A second meeting was scheduled for December 3,             
          2001, at 10 a.m.  Further, the parties have stipulated that                 
          petitioners failed to appear for this second meeting, and that a            
          representative of petitioners telephoned the settlement officer             
          later in the day to ask that the meeting be rescheduled.  Rather            
          than schedule a third meeting, the settlement officer elected               
          instead to close the case and issue a determination letter.                 
               We find it unnecessary to decide whether, in these                     
          circumstances, petitioners’ right to a hearing under section                
          6330(b) was infringed upon when respondent’s settlement officer             
          refused to offer petitioners a third opportunity for a face-to-             
          face meeting.  The issues that petitioners have raised herein and           
          indicated they would have raised in a face-to-face                          
          meeting--namely, the correctness of the 1991 deficiency and the             






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