- 5 -
not advise petitioner or Mr. Wagner of respondent’s post-Keene
policy that a taxpayer would be permitted to audio record a face-
to-face section 6330 hearing but not a telephone hearing.
The telephone hearing scheduled for August 18, 2003, was
rescheduled for August 20, 2003, and was convened on that date.
At the beginning of the hearing, Mr. Wagner again informed the
Appeals officer that he intended to audio record the hearing, and
the Appeals officer again advised Mr. Wagner that the Appeals
Office’s policy did not permit audio recording. Mr. Wagner and
the Appeals officer agreed that they would consider the hearing
started and then terminated, with no substantive issues
discussed, because the Appeals officer would not permit audio
recording. After Mr. Wagner and the Appeals officer agreed the
hearing was terminated, the Appeals officer notified Mr. Wagner
that she would issue a notice of determination based on the
information in her administrative file. The parties stipulated
that petitioner would have continued with the telephone hearing
had he been permitted to audio record it.
On September 16, 2003, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) to petitioner. The notice
of determination informed petitioner that respondent had
determined that a levy was appropriate to collect the 1998 tax
liability.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011