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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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