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this chapter (other than a tax matter described in
paragraph (c) of this section) unless--
(i) The party, prior to filing a petition in the
Tax Court * * * participates * * * in an Appeals office
conference; or
(ii) If no Appeals office conference is granted,
the party, prior to the issuance of a statutory notice
in the case of a petition in the Tax Court * * *
(A) Requests an Appeals office conference in
accordance with �� 601.105 and 601.106 * * *; and
(B) Files a written protest if a written protest
is required to obtain an Appeals office conference.
Respondent’s 30-day letter sent to petitioner states:
If you do not accept our findings, we recommend
that you request a hearing with our Office of Regional
Director of Appeals. * * *
If the proposed change is more than $2,500 but is
* * * $25,000 or less for any tax period, you must give
a brief written statement of the disputed issues.
If the proposed change to you [sic] tax (including
penalties) is MORE THAN $25,000 for any tax period, we
will require a written protest. Follow the
instructions in the enclosed Publication 5, which also
explains your appeal rights.
According to Publication 5, a taxpayer must follow the
instructions in the 30-day letter to receive an Appeals Office
conference. Publication 5 directs a taxpayer to file its formal
written protest or small case request with the office named in
the 30-day letter to receive an Appeals Office conference.
Publication 5 contains the same monetary ranges as the 30-day
letter, which instructs the taxpayer to file either a small case
request or formal written protest. Additionally, to complete a
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Last modified: May 25, 2011