Dominic Calafati - Page 5

                                        - 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              

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