Carolyn D. Ramirez - Page 6

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          By letter dated August 13, 2002, the Appeals officer sent                   
          petitioner the following explanation of his decision in issuing             
          the Notice of Determination:                                                
               On August 5, 2002 I closed your case for issuance of                   
               our Determination Letter.  On August 12, 2002 that                     
               letter was mailed.  I will place the information you                   
               recently sent us in the administrative file and ask                    
               that someone in our Automated Collection System (ACS)                  
               Department take a look at it for purposes of                           
               considering the next collection step.                                  
               You have a choice concerning our Determination Letter.                 
               You can file a petition with the United States Tax                     
               Court and ask either the government’s attorney or the                  
               Judge to have someone look at your information or you                  
               can do nothing and let someone with our ACS Department                 
               look at it once your case is returned to them.                         
               Upon receiving the Notice of Determination, petitioner wrote           
          the following letter to the Appeals officer on August 22, 2002:             
              I received your notice dated August 12, 2002.  I have                   
              two concerns:  (1) when we spoke on July 11, 2002, I                    
              distinctly remember the due date being July 31, 2002.                   
              I remember we went back & forth on the due date but                     
              this was the date we decided on * * * (2) I submitted                   
              all the information on July 31, 2002.  I dropped it in                  
              the box at the main post office.  The mail handler had                  
              to [purchase] 11 -37� stamps on the envelope.  That                     
              envelope was returned - see attached.                                   
          Attached to petitioner’s letter was a copy of a notice from the             
          Postal Service, which bore a postmark dated in August 2002.  The            
          copy submitted to the Court is difficult to read, and the date in           
          August is illegible.  The Postal Service notice states:                     
              We regret that your mail is being returned to you because               
              of heightened security measures.  All domestic mail,                    
              weighing 16 ounces or over, that bears stamps * * *                     







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