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1(d)(2), Q&A-D7, Proced. & Admin. Regs., which provides that, if
a taxpayer receives notice that a lien or levy has been filed and
requests a hearing at respondent’s Appeals Office, the taxpayer
must be offered an opportunity for a hearing at the Appeals
Office closest to the taxpayer’s residence. See Katz v.
Commissioner, 115 T.C. at 335-336; sec. 301.6320-1(d)(2), Q&A-D7,
Proced. & Admin. Regs.
We conclude that petitioner requested a hearing by filing
Form 12153. Respondent was required to provide him with an
opportunity for a hearing at the Appeals Office closest to his
residence. Katz v. Commissioner, supra; sec. 301.6320-1(d)(2),
Q&A-D7, Proced. & Admin. Regs.5
3. Whether Petitioner Was Provided an Opportunity for a Hearing
at the Appeals Office Closest to His Residence
Petitioner lived in New Orleans when he requested a hearing
under section 6320(b). Respondent had an Appeals Office in New
Orleans at all times relevant to this case. Respondent did not
4(...continued)
representative, or some combination thereof. * * *
5 Sec. 301.6320-1(d)(2), Q&A-D7, Proced. & Admin. Regs.,
provides:
Q-D7. If a taxpayer wants a face-to-face CDP hearing, where
will it be held?
A-D7. The taxpayer must be offered an opportunity for a
hearing at the Appeals Office closest to taxpayer’s residence * * *
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Last modified: May 25, 2011