- 2 -
to consider petitioner’s offer in compromise at a hearing as
required by section 6330(b) and (c)(2)(A)(iii).
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. When she filed her
petition, petitioner resided in Fresno, California.
On February 8, 2002, respondent issued to petitioner a
Notice of Intent to Levy under IRC 6330 (notice) with regard to
petitioner’s unpaid Federal income tax liability for 1999. In
response to the notice, petitioner filed a Form 12153, Request
for a Collection Due Process Hearing (CDP hearing), on February
16, 2002. Petitioner stated on the Form 12153 that she wanted to
explore an offer in compromise. Petitioner’s case was assigned
to an Appeals officer (the Appeals officer) from respondent’s
Appeals office in Fresno, California (the Appeals office). On
June 13, 2002, the Appeals officer wrote petitioner the following
letter:
This is to advise you that I have been assigned your
request for a Collection Due Process Hearing. I have
scheduled your hearing for Wednesday July 10, 2002 at
10:00 AM. The Collection Due Process hearing may be
conducted via telephone, correspondence or in a personal
conference. To facilitate our discussions, I am
enclosing an explanation of the Appeals process for
Collection Due Process cases.
I suggest we conduct the hearing by telephone. Please
call me at the scheduled date and time. * * * If you
would like to conduct the hearing in a different way,
such as in person or by correspondence please let me
know before the hearing date. If the date and time is
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011