-4- Petitioner did not respond to respondent’s initial letter by the July 23, 2004, stated deadline. On July 27, 2004, petitioner mailed a letter to respondent’s Appeals officer in which petitioner again refused to identify specific issues,2 and in which petitioner reiterated his intent to tape record the hearing. In his letter, petitioner erroneously claimed that, if he identified specific issues prior to the hearing, he somehow would be precluded from adding to those issues at the hearing. On July 29, 2004, and on August 2, 2004, the Appeals officer attempted to contact petitioner by telephone. On both dates, no one answered at the phone number petitioner had provided. Later on August 2, 2004, the Appeals officer mailed another letter to petitioner (final letter) in which the Appeals officer noted that petitioner had not yet identified specific issues, and the Appeals officer again requested that petitioner identify specific issues to be considered at a face-to-face hearing. The final letter also set an August 12, 2004, deadline for petitioner to identify specific issues or the Appeals officer would decide petitioner’s appeal based solely on information already in the administrative file. 2Petitioner now contends that he did not receive respondent’s notice of deficiency relating to 2000 and therefore that, at the Appeals Office hearing, he should have been entitled to challenge the underlying tax liability. Petitioner, however, did not raise the issue of receipt of respondent’s notice of deficiency in his communications with the Appeals Office.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011