Michael E. Vierow - Page 3

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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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