Gregory Drake - Page 27

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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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