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Upon receiving the Appeals officer’s letter, petitioner did
not telephone the Appeals officer, but instead wrote a letter to
the Taxpayer Advocate, dated August 30, 2001, and sent a copy to
the Appeals officer. The letter was essentially a record of
petitioner’s contacts with the Internal Revenue Service regarding
his 1997 tax liability. At the end of this letter, petitioner
stated that the earliest he could meet with anyone would be
September 17, 2001, as he was seeking work and his schedule was
full. The Appeals officer’s copy of petitioner’s August 30,
2001, letter did not reach the Appeals officer until the
afternoon of September 5, 2001, which was after the 9:30 a.m.
time scheduled for the hearing that day.
When petitioner did not appear for the scheduled hearing,
the Appeals officer held a correspondence hearing. As a result
of this hearing, the Appeals officer determined the proposed levy
was legally and procedurally correct. That same day, the Appeals
officer sent petitioner a letter, dated September 5, 2001,
notifying him of the result of the hearing. Attached to this
letter was a transcript of petitioner’s 1997 tax liability. The
Appeals officer also stated in the letter that petitioner had not
proposed any collection alternatives, so the Appeals Office would
be issuing a determination letter and petitioner should call if
he had any questions.
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Last modified: May 25, 2011