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and complained about “the failure to send 4340 forms with 23C
dates”.2
On March 11, 2005, the Appeals officer assigned to
petitioner’s case, Kathleen Derrick (Ms. Derrick), mailed to
petitioner a letter entitled We Received Your Request for A
Collection Due Process Hearing And We Need To Advise You On
Procedures. The letter informed petitioner that the issues
petitioner raised in its Appeals hearing request on Form 12153
were frivolous or groundless. The letter provided:
Appeals does not provide a face-to-face conference if
the only items you wish to discuss are those mentioned
above. You may, however, have a telephone conference
or discuss with us by correspondence any relevant
challenges to the filing of the notice of federal tax
lien or the proposed levy.
* * * * *
If you are interested in receiving a face-to-face
conference, you must be prepared to discuss issues
relevant to paying your tax liability. These include,
for example, offering other ways to pay the taxes you
owe, such as an installment agreement or offer in
compromise. The Internal Revenue Manuel determines
whether Appeals can accept your proposal. If you wish
to have a face-to-face conference, please write me
within 15 days from the date of this letter and
describe the legitimate issues you will discuss.
The letter further provided that petitioner was scheduled for a
telephonic hearing on March 30, 2005, at 10 a.m. Additionally,
the letter instructed petitioner to fill out Form 433-B,
2A “23C date” is the date on which the actual assessment of
the tax liability was made.
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Last modified: November 10, 2007