Leonard O. Parker, Jr. - Page 6

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          At trial, respondent contended:  (a) Respondent was not required            
          to provide petitioner an opportunity for a hearing at the Appeals           
          Office closest to petitioner’s residence, and (b) petitioner                
          waived any right to a hearing because petitioner had a telephone            
          conference with Appeals in lieu of attending the conference in              
          Jackson, Mississippi.  Parker v. Commissioner, T.C. Memo. 2004-             
               The Court ruled respondent was required to provide                     
          petitioner with an opportunity for a hearing at the Appeals                 
          Office closest to his residence.  Id.  Further, the Court found             
          petitioner did not explicitly or implicitly waive his right to a            
          hearing at respondent’s Appeals Office.  Id.  The Court remanded            
          the case to respondent’s Office of Appeals with instructions to             
          offer petitioner a face-to-face conference at the Appeals Office            
          closest to petitioner’s residence in Southern California.  Id.              
               On December 15, 2004, petitioner met with Settlement Officer           
          Adlai Climan (Mr. Climan) at respondent’s Los Angeles Appeals               
          Office.  This office was the closest Appeals Office to                      
          petitioner’s Southern California address.                                   
               At the hearing, petitioner asserted the amounts due were               
          incorrect, the assessments for tax years 1992-94 were untimely,             
          the NFTL was not timely filed, and the penalties and interest on            
          the assessed liabilities should be abated.  In addition,                    
          petitioner asserted his April 7, 1994, bankruptcy filing barred             

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