-6- activity log that he had reviewed respondent’s transcripts of account for petitioner’s tax year 1989 and 1990, including Forms 4340, Certificates of Assessments, Payments, and Other Specified Matters, and concluded that respondent had followed proper administrative and procedural requirements. The Appeals officer received and read petitioner’s May 15, 2002, letter on May 22, 2002. Even though he told petitioner he would reschedule the hearing at petitioner’s request, the Appeals officer did not do so. On June 4, 2002, respondent issued a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. In it, respondent determined that respondent’s collection action with respect to petitioner’s tax years 1989-90 and 1999 was proper. OPINION A. Whether Respondent Provided Petitioner an Opportunity for a Hearing Under Section 6330(b) Respondent contends that petitioner was given an opportunity to have a hearing in this case. We disagree. The Appeals officer invited petitioner to attend a hearing and said he would reschedule it if it were inconvenient for petitioner to attend. Petitioner timely requested that it be rescheduled. As a result of telling petitioner he would reschedule the hearing at petitioner’s request, and then not doing so, the Appeals officer denied petitioner the opportunity for a hearing on the issues petitioner had identified in his request for aPage: Previous 1 2 3 4 5 6 7 8 9 Next
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