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presence, and that “The Appeals Office did not grant a fair
hearing”.
Petitioner further explains that in preparation for his
meeting with Ms. Sharp and Mr. Rosenblatt he called Ms. Diane
Hakam, Department Manager of the Taxpayer Advocate’s Office in
Holtsville, Long Island. As noted above and in our previous
opinion, petitioner alleges that in October 1999, Ms. Ogle of the
Taxpayer Advocate’s Office provided petitioner a final payout
figure of $14,172 for resolution of his outstanding tax
obligations for 1995 and 1996. Petitioner states that Ms. Hakam
informed him that a file was not available for his examination
because the records in question had been destroyed after one year
in accordance with office policy. Petitioner explains that he
“did not request such a document in 10/99 because I trusted the
taxes were payed in full, relying on representation of the
Taxpayer Advocate’s Office.” Petitioner describes his
attachments to his status report as a “fax from me to Ms. Ogle
confirming the final tax payment due” and four other documents
allegedly showing his correspondence with employees of the IRS
prior to the “final payment date”.
Respondent’s status report states that petitioner appeared
for hearing at the Long Island, New York Appeals Office so that
the settlement officer might consider the specific issues
mentioned in our Order dated April 9, 2004. Respondent further
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