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that she did not owe the taxes because the liability had been
discharged in a Chapter 7 bankruptcy proceeding in 2002.
C. Petitioner’s Appeals Hearing
During the telephonic hearing, petitioner told Appeals
Officer Carolyn Jackson (Ms. Jackson) that she had previously
given the auditor all of the information requested. She stated
that as soon as she received the notice of deficiency, she gave
the auditor additional information to verify the earned income
credit, dependency exemptions, and head of household filing
status. Petitioner said she never heard from the auditor again
regarding her consideration of the additional information. She
also stated that she had filed for bankruptcy and had been told
that her slate had been wiped clean.
Ms. Jackson discussed with petitioner installment agreements
and the possibility of placing her account in “currently not
collectible” status. When petitioner indicated that she wanted
to discuss the options in greater detail at a later date, Ms.
Jackson set up a telephonic conference for March 1, 2004. On
that date, petitioner called and indicated she would not be able
to participate because her daughter was ill. Ms. Jackson
rescheduled the conference to March 15, 2004. On that date, Ms.
Jackson was unable to contact petitioner, and petitioner did not
contact her to reschedule or to discuss the case. On June 16,
2004, Ms. Jackson sent petitioner a notice of determination
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