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On June 23, 2003, respondent’s Appeals officer sent
petitioners’s designated representative a letter scheduling the
date and time of the requested hearing for July 10, 2003, at
9 a.m. Attached to the letter was a copy of petitioner’s Form
4340, Certificate of Assessments, Payments, and Other Specified
Matters, with respect to petitioner’s 1997 tax year. The Appeals
officer also noted in the letter that petitioner’s representative
could request a phone conference instead of an in-person meeting
if he preferred.
Neither petitioner nor her designated representative
appeared for the scheduled conference. Further neither
petitioner nor her representative attempted to schedule an
alternative conference date. At this point, the Appeals officer
reviewed petitioner’s certified transcript and the information in
petitioner’s file. After this review, respondent issued a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330, dated July 17, 2003, wherein respondent
determined the proposed collection action was appropriate.
Petitioner asserts that the Appeals officer refused to allow
petitioner to make a recording of the administrative hearing.
Respondent, however, points out that neither petitioner nor her
representative made a request to record an administrative
hearing. Respondent also reiterates the fact that neither
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Last modified: May 25, 2011