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levy to collect the unpaid tax liabilities and of petitioner’s
right to request a hearing with respondent’s Appeals Office. On
September 7, 2004, petitioner submitted a Form 12153, Request for
a Collection Due Process Hearing.
Petitioner’s hearing request was initially assigned to
Settlement Officer Adlai Climan (Mr. Climan). On April 22, 2005,
Mr. Climan drafted an Appeals Case Memorandum that verified that
respondent’s assessments were timely and that petitioner had
received notice and demand for payment for each year in
accordance with section 6303.4 On May 4, 2005, Mr. Climan mailed
to petitioner a letter scheduling a face-to-face conference for
May 18, 2005, at the Los Angeles, California, Appeals Office.
Petitioner requested that the conference be held in Thousand
Oaks, California, because it was closer to his place of
residence. Mr. Climan initially rejected petitioner’s request
because Mr. Climan’s office was located in Los Angeles, and no
settlement officers worked at the Thousand Oaks office. After
receiving another request from petitioner to move the meeting to
Thousand Oaks, however, petitioner’s case was reassigned to
4 Sec. 6303 requires that the Secretary, within 60 days of
making an assessment of tax pursuant to sec. 6203, give notice to
the person liable for the unpaid tax, stating the amount due and
demanding payment.
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Last modified: May 25, 2011