- 9 - 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 * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011