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Forms 4340, Certificate of Assessments, Payments and Other
Specified Matters, for each of the years in issue.3
Prior to the hearing, by a letter dated July 15, 2003,
petitioner informed the settlement officer that in light of the
recent opinion of this Court in Keene v. Commissioner, 121 T.C. 8
(2003), she wished to record the hearing. The settlement officer
sent petitioner a response on July 21, 2003, advising that
respondent’s procedures barring recording had not changed and
that petitioner would not be allowed to make an audio or
stenographic recording of the hearing.
Petitioner appeared for the scheduled conference on July 24,
2003, but the hearing did not proceed when petitioner was not
permitted to record. The settlement officer informed petitioner
that he would make his determination based on the information in
her file. Thereafter, on July 31, 2003, respondent issued the
aforementioned Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 to petitioner sustaining
the proposed levy action.
Petitioner’s petition disputing the notices of determination
was filed on September 5, 2003, and reflected an address at 1836
West Mohave, Phoenix, Arizona 85007. In the petition, the sole
3 Although the June 11, 2003, letter contains a
typographical error referring to the enclosures as “Certified
Transcripts for 1994, 1995, 1996 and 1997”, the actual enclosures
sent were for the pertinent 1993 through 1996 years.
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Last modified: May 25, 2011