Leonard O. Parker, Jr. - Page 5

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          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            
               Petitioner timely filed a petition with this Court.                    
          The case was tried before this Court in Los Angeles, California.            

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