- 4 - 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 datedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011