- 7 - to evaluate and correct the errors in the Forms 4340 that were provided to petitioner during the administrative hearing and provide petitioner a further opportunity to offer collection alternatives. During the remand, petitioner’s case was reassigned (at petitioner’s request) from Officer Clark to Appeals Officer Linda Kramer (Officer Kramer). On October 12, 2004, Officer Kramer met with petitioner for the purpose of conducting an administrative hearing. The hearing was terminated, however, when petitioner informed Officer Kramer that he desired to obtain legal counsel. In a letter to Officer Kramer dated October 22, 2004, petitioner stated that he was relying on section 7521(b)(2) and Keene v. Commissioner, 121 T.C. 8 (2003), to argue that the Appeals Office was obliged to terminate his administrative hearing when petitioner stated that he wished to consult with an attorney. The Appeals Office issued to petitioner a supplemental determination notice on November 17, 2004. In the supplemental notice, the Appeals Office concluded that it was appropriate to proceed with the proposed levy for 1998 and 1999. Respondent filed with the Court a status report on November 23, 2004, describing the various actions that were taken while the matter was on remand. Respondent filed a Motion for Summary Judgment on November 24, 2004. Respondent’s motion included as exhibits Forms 4340 for 1998 and 1999, dated September 20, 2004.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011