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In a letter dated October 28, 2002, Settlement Officer Craca
informed petitioner that his case had been transferred back to
the Appeals Office in Washington, D.C., for resolution. She
informed him that a hearing under section 6330 was scheduled for
November 21, 2002, and again requested that petitioner submit
both “A completed Offer in Compromise package (Forms 656, 433A
and 433B)” and a 2001 tax return.
Petitioner, through a representative, requested in a letter
dated November 18, 2002, a continuance of the hearing scheduled
for November 21, 2002. Petitioner indicated that his tax return
preparer was “in California on vacation until after the
Thanksgiving holidays,” and that said preparer had all the
documentation necessary for petitioner to complete forms
concomitant to an offer in compromise and the requested tax
return.
In a letter dated November 19, 2002, respondent denied
petitioner’s request to postpone the hearing. Petitioner renewed
his request on November 20, 2002, citing delay by the Government,
the unavailability of petitioner’s tax return preparer, and a
variety of personal reasons. Respondent again denied the
request.
Respondent issued petitioner a notice of determination dated
December 30, 2002.
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