-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.
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Last modified: May 25, 2011