Leonard O. Parker, Jr. - Page 2

                                        - 2 -                                         
          and/or 63301 in which respondent determined the filing of a tax             
          lien relating to those tax years was appropriate.                           
               Petitioner timely requested a hearing under section 6320(b).           
          Respondent informed petitioner by letter that respondent had                
          scheduled a conference at respondent’s Appeals Office in Jackson,           
          Mississippi, to be held 8 days after the date respondent sent the           
          letter.  In the letter, respondent requested that petitioner                
          provide, not later than 3 days after the date respondent sent the           
          letter, any documents he wished to have considered at that                  
          conference.  Jackson, Mississippi, is about 180 miles from New              
          Orleans.  Respondent has an Appeals Office in New Orleans but did           
          not schedule the conference there.                                          
               The sole issue for decision is whether respondent was                  
          required to provide petitioner an opportunity for a hearing at              
          the Appeals Office closest to petitioner’s residence.  We hold              
          that respondent was.  See Katz v. Commissioner, 115 T.C. 329,               
          335-336 (2000); sec. 301.6320-1(d)(2), Q&A-D7, Proced. & Admin.             
          Regs.  We will remand this case to respondent with instructions             
          to comply with this requirement.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts are stipulated and are so found.                     

               1  Section references are to the Internal Revenue Code in              
          effect during the relevant years.                                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011