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(1) The Appeals Office would not offer a face-to-face
hearing if the only issues that petitioner wanted to address were
frivolous or groundless;
(2) the hearing request was not received within the 30-day
period provided in section 6330(a)(3)(B), but petitioner could
raise the issue of the timeliness of his request at the hearing;
(3) petitioner should complete and submit Form 433-A,
Collection Information Statement for Individuals, with the
documents required by the form; and
(4) petitioner should provide proof that he filed his 2001
and 2002 Federal income tax returns.
Petitioner responded to the November 13, 2003, letter by
letter dated November 20, 2003. In that letter, petitioner
requested a face-to-face hearing and stated that he had post
office receipts to prove that he had timely requested a hearing
under section 6330. By letter dated January 6, 2004, Ms.
Chadwell scheduled a face-to-face hearing for January 21, 2004.
The hearing date was subsequently changed to February 23, 2004,
at petitioner’s request.
Petitioner’s hearing under section 6330 was held on February
23, 2004. The hearing was audiotaped and transcribed. At the
hearing, Ms. Chadwell reminded petitioner of her prior requests
for information, including a completed Form 433-A, and of her
admonition that she would not consider frivolous or groundless
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Last modified: May 25, 2011