- 5 -
2002 (i.e., 8 days after the letter was sent), in respondent’s
Jackson, Mississippi, Appeals Office. Jackson is approximately
180 miles from New Orleans.
Appeals requested petitioner to provide any documents to be
considered during the Jackson hearing no later than 3 days after
the date Appeals sent the letter. Further, Appeals did not
inform petitioner the proposed conference was the hearing under
section 6320(b) petitioner had requested when he submitted the
Form 12153.
Petitioner received the Appeals’ March 19, 2002, letter on
March 25, 2002, 2 days before the date Appeals had chosen for the
conference. The same day, petitioner faxed a response to Appeals
stating he was unable to attend or adequately prepare for the
conference in Jackson, and the Appeals deadline for sending
affidavits and documents in advance of the conference had already
passed. Petitioner stated he would be available for the
conference via telephone. Petitioner and Appeals held their
telephone conference on March 27, 2002.
On February 12, 2003, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) in which
respondent determined the filing of the tax lien for 1992-94 was
appropriate.
Petitioner timely filed a petition with this Court.
The case was tried before this Court in Los Angeles, California.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011