Kevin Thompson - Page 4

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          schedule his hearing.  In a letter dated August 4, 2002,                    
          petitioner informed the Appeals officer that he intended to audio           
          record his hearing and bring a court reporter to make a                     
          stenographic recording of the hearing.  On August 15, 2002, the             
          Appeals officer sent petitioner a letter informing him that as of           
          May 2, 2002, the Appeals Office no longer allowed taxpayers to              
          make audio or stenographic recordings of hearings.  The Appeals             
          officer also sent him a copy of a Memorandum for All Appeals Area           
          Directors dated May 2, 2002, from the Acting Chief of the Office            
          of Appeals outlining the new policy.  See Keene v. Commissioner,            
          121 T.C. 8, 12 (2003), for the text of the memorandum.                      
               On September 9, 2002, petitioner’s hearing was held.                   
          Petitioner was not permitted to audio record or stenograph the              
          hearing.  At the hearing, the Appeals officer provided petitioner           
          with a copy of Form 4340, Certificate of Assessments, Payments,             
          and Other Specified Matters, for his 1997 year.  The Appeals                
          officer also explained to petitioner that he could offer                    
          collection alternatives at his hearing, which would be considered           
          only if he was current in his filing requirements for years other           
          than 1997.  On September 10, 2002, the Appeals officer sent                 
          petitioner a letter addressing some issues raised during the                
          hearing and a copy of Delegation Order No. 196 (Rev. 4), which              
          delegates the authority to sign notices of Federal tax liens to             
          IRS Compliance Managers.  Petitioner replied in a letter dated              

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