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On October 18, 2002, petitioner filed a Form 12153, Request
for a Collection Due Process Hearing, regarding his 1994, 1995,
1996, 1997, and 1998 tax years (hearing request). Petitioner
attached the hearing notice and a 12-page letter to the hearing
request. Petitioner argued that respondent failed to follow the
requirements of applicable law and administrative procedure.
On February 24, 2003, respondent’s San Francisco Appeals
Office sent petitioner a letter stating that it had received his
hearing request and explaining the hearing process.
On May 7, 2003, Appeals Officer James Chambers sent
petitioner a letter requesting that petitioner contact him to
schedule a section 6330 hearing (hearing). Appeals Officer
Chambers advised petitioner that the hearing could be held in
person, by telephone, or by correspondence.
On May 19, 2003, petitioner sent Appeals Officer Chambers a
letter requesting an in-person hearing closer to his home than
San Francisco, California. Petitioner suggested that the hearing
be held at respondent’s office in Eureka, California.2
On June 16, 2003, Appeals Officer Chambers sent petitioner a
letter stating that the San Francisco Appeals Office was the
closest option for an in-person hearing. Appeals Officer
Chambers again offered petitioner the option of a telephone
2 From the record, it is unclear whether respondent had an
Appeals Office in Eureka, California.
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Last modified: May 25, 2011