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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.
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