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he needed to file his delinquent returns by August 31, 2000, as a
condition to discussing collection alternatives such as an
installment agreement or an offer in compromise.
On October 3, 2000, Appeals Officer Hirsch telephoned
petitioner and attempted to conduct a section 6320 hearing, at
which time petitioner requested an extension of time to review
his notes. During this conversation, Appeals Officer Hirsch
granted petitioner’s request for an extension to file his
delinquent returns until November 30, 2000. Petitioner agreed to
conduct the hearing by telephone rather than in person within 1
week of submitting his delinquent returns.
On October 4, 2000, Appeals Officer Hirsch sent petitioner a
letter scheduling a telephone hearing for December 8, 2000.
On December 8, 2000, Appeals Officer Hirsch telephoned
petitioner and conducted petitioner’s section 6320 hearing, even
though petitioner had not yet filed his delinquent returns.
There is no evidence in the record that petitioner at any time
either requested that the hearing be held in person or objected
to the holding of a hearing by telephone.
On July 26, 2001, respondent’s Appeals Office issued a
notice of determination concerning collection actions informing
petitioner of the determination not to withdraw the NFTL. As of
that date, petitioner had not appealed the rejection of his
installment agreement request.
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