- 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