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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...)
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