- 20 - addition, with regard to his desire to submit information in person, petitioner had been unable to attend any of the previously proposed conferences and at no time communicated to Ms. Carter a readiness or willingness to meet after the June 26, 2002, date. Moreover, the above-quoted regulations confirm that a conference between an Appeals officer and a taxpayer’s representative, not the taxpayer himself, may fulfill the statutory directive for a hearing. Hence, at the time respondent issued the notice of determination, Ms. Carter had addressed in writing the sole statute of limitations issue raised by petitioner for 1985 in his Form 1215312 and had held a face-to-face conference with petitioner’s representative, the consequences of which Mr. Lynch clearly understood and had communicated to petitioner. In these circumstances, the Court is satisfied that, with respect to 1985, petitioner was offered and received a full and fair hearing which complied with the requirements of section 6330. 2. Review of Underlying Liabilities As previously indicated, the petition filed in this case focused solely on the contention that petitioner had not been afforded a proper hearing for purposes of section 6330. 11(...continued) shoulder their burden to pay timely. 12 See supra note 9.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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