- 27 - hearing on remand together constitute the taxpayer’s administrative hearing for purposes of section 6330.14 See Parker v. Commissioner, supra (“In appropriate circumstances, we may remand a case to the Appeals Office for further investigation and consideration of the taxpayer’s contentions.”). In the instant case, respondent’s notice of determination, dated March 13, 2006, is properly treated as a supplemental notice of determination. Petitioner continues to dispute the issues raised in the original notice of determination and has raised additional issues with respect to the supplemental notice of determination. As petitioner previously had filed a petition under section 6330 with this Court, the determinations of respondent’s Appeals Office are ripe for judicial review. Sec. 6330(d)(1). We separately address below the issues raised by petitioner with respect to the original notice of determination and the supplemental notice of determination. III. Issues With Respect to the Initial Section 6330 Hearing We now address the issues that were raised by petitioner with respect to the initial hearing but not addressed in Drake I.15 14We note that a person is entitled to only one notification pursuant to sec. 6330(a)(1) and one administrative hearing pursuant to sec. 6330(b)(2). 15Because we held in Drake I that the ex parte communication between Advisor Gordon and Settlement Officer O’Shea on Jan. 30, (continued...)Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011