Ariel J. Dorra - Page 2

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          meaning of section 6320(b) or 6330(b).1  In particular,                     
          petitioner contends that telephone contacts between himself, his            
          representative, and the Appeals officer do not constitute a                 
          “hearing” as contemplated in section 6320(b).                               
          Background                                                                  
               Petitioner filed 1997, 1999, and 2000 Federal income tax               
          returns, but failed to pay all of the reported tax liabilities.             
          The liabilities were assessed by respondent and on March 25,                
          2002, petitioner was sent a Notice of Federal Tax Lien Filing And           
          Your Right to a Hearing Under I.R.C. 6320.  A Notice of Federal             
          Tax Lien had been filed and recorded on March 20, 2002, and on              
          March 28, 2002, petitioner entered into an installment agreement            
          to pay his outstanding tax liabilities.  After the filing of the            
          Notice of Federal Tax Lien and entering into the installment                
          agreement, petitioner sought to have the Notice of Federal Tax              
          Lien removed.                                                               
               On May 1, 2002, petitioner requested a hearing by submitting           
          a Form 12153, Request For A Collection Due Process Hearing, and             
          on November 25, 2002, respondent’s Appeals officer sent a letter            
          offering to schedule a hearing.  In a December 13, 2002, letter,            
          petitioner’s representative, a lawyer under a power of attorney             
          from petitioner, set forth the relief sought by his client, to              


               1 Section references are to the Internal Revenue Code in               
          effect for the period under consideration.  Rule references are             
          to the Tax Court’s Rules of Practice and Procedure.                         




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