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to Magee stating that he was unable to attend or adequately
prepare for the conference in Jackson, and that Magee’s deadline
for sending affidavits and documents in advance of the conference
had already passed. He stated that he “will be available for the
conference via telephone”, but he did not waive his right under
section 301.6320-1(d)(2), Q&A-D7, Proced. & Admin. Regs., to have
a hearing at respondent’s office.
D. The March 27, 2002, Telephone Call and Events Leading to
Respondent’s Determination
Petitioner and Magee spoke by telephone on March 27, 2002.
During the telephone call, petitioner said, inter alia, that the
notice of Federal tax lien had been filed prematurely and that
the Taxpayer Advocate’s Office had placed a hold on collection
actions.
Petitioner wrote letters and sent faxes to Magee and other
employees of respondent between March 27 and May 2, 2002.
Petitioner asked that respondent provide him with copies of
respondent’s records relating to his offers in compromise,
requests for abatement of interest and penalties, and requests
for assistance from the Taxpayer Advocate’s Office, and he told
Magee that the amount that respondent sought to collect for 1992-
94 was incorrect because respondent had not applied a credit from
a later year to those years.
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Last modified: May 25, 2011