-3-
Respondent periodically mailed to petitioner additional
collection notices relating to this assessment.
On January 29, 2004, respondent mailed to petitioner a
notice of intent to levy relating to petitioner’s outstanding
2000 Federal income taxes, penalties, and interest, showing a
total due from petitioner of $43,883.
On February 17, 2004, respondent received petitioner’s
request for an Appeals Office hearing in which petitioner stated
that he: (1) Had issues to discuss in connection with the
notice; (2) expected to discuss those issues at a face-to-face
hearing; and (3) planned to audiotape the hearing. Petitioner,
however, did not identify a single specific issue in his Appeals
Office hearing request.
On July 8, 2004, respondent’s Appeals officer mailed an
initial letter (initial letter) to petitioner in which he
informed petitioner of an Appeals Office policy against
conducting face-to-face hearings with taxpayers where taxpayers
do not identify specific issues prior to the hearing. The
Appeals officer provided petitioner with examples of appropriate
issues, requested that petitioner by July 23, 2004, provide
written notice of the issues petitioner wished to raise, warned
petitioner against making frivolous arguments, and proposed
alternate telephonic hearing dates -- July 29, 2004, and
August 2, 2004.
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Last modified: May 25, 2011