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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.
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