- 12 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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