Michael Stein - Page 13

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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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