Omar Urbina Pineda - Page 7

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               The Appeals officer sent petitioner a letter dated June 29,            
          2004, scheduling a hearing for July 12, 2004.  The letter further           
          directed petitioner to file his 2002 tax return and to provide              
          proof of estimated tax payments for the taxable years 2002, 2003,           
          and 2004.  On July 12, 2004, the Appeals officer received the               
          June 29, 2004 letter, which was returned to him marked “not                 
          deliverable as addressed, unable to forward”.                               
               On that same day, the Appeals officer telephoned petitioner            
          at which time petitioner expressed an interest in an installment            
          agreement.  The Appeals officer directed petitioner to (1) file             
          petitioner’s 2002 and 2003 returns by July 28, 2004; (2) make               
          estimated tax payments for 2004; and (3) complete Form 433-A,               
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals.  The Appeals officer then scheduled another           
          hearing for July 21, 2004.  On July 13, 2004, the Appeals officer           
          sent petitioner a letter documenting the terms established in               
          their conversation.                                                         
               On July 14, 2004, petitioner telephoned the Appeals officer            
          to reschedule the hearing for July 16, 2004.                                
          D.  Petitioner’s CDP Hearing                                                
               On July 16, 2004, petitioner attended a hearing with the               
          Appeals officer.  At the hearing, petitioner again expressed an             
          interest in entering into an installment agreement.  He requested           







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