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May 29, 2002, petitioner timely requested a hearing by filing a
Form 12153, Request for a Collection Due Process Hearing, in
which he listed the Wanda Avenue address as his address.
On September 4, 2002, the settlement officer assigned to
petitioner's case mailed an acknowledgment letter and Appeals
process flyer to petitioner at the Wanda Avenue address. An
assignment letter, requesting that petitioner contact the Appeals
Office to schedule a hearing, was sent to petitioner's Wanda
Avenue address on September 12, 2002. After no response was
received with respect to the foregoing letters, the settlement
officer confirmed the Wanda Avenue address as the address of
petitioner recorded on respondent's Integrated Data Retrieval
System (IDRS), and sent a second assignment letter to the Wanda
Avenue address on October 2, 2002, requesting that petitioner
contact her by November 5, 2002. Petitioner responded to this
letter by telephoning the settlement officer on November 5, 2002;
they conducted a hearing over the telephone at that time.
Petitioner advised the settlement officer of his belief that
he was due a refund with respect to his 1991 tax year and of his
desire to file a corrected return for 1991. (Petitioner claimed
to have filed previously for 1991.) Petitioner requested that
the settlement officer provide him a return form for completion
and filing. Petitioner further requested return forms for 1997
and 2001 so that he could become current in his filing
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