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Collection Information Statement for Businesses, and return it by
March 28, 2005, so that collection options could be considered.
Ms. Derrick attached to the letter “literal transcripts” of
petitioner’s tax liability.
In response, petitioner mailed a letter, dated March 24,
2005, to Ms. Derrick, which provided that petitioner was
requesting a “face to face conference” and “The legitimate issues
we wish to discuss are delay and issues of mishandling of this
matter.” A telephonic hearing was held on March 30, 2005. That
same day Ms. Derrick mailed to petitioner a letter that requested
specific documents and information that would facilitate the
Appeals Office’s determination as to whether petitioner was
entitled to a face-to-face hearing. The letter requested, inter
alia, that petitioner complete and return Form 433-B, a copy of
which was attached, and explain with supporting documentation why
petitioner did “not owe a tax liability for the Form 1120 for the
tax year 2000.” The letter informed petitioner that if
Ms. Derrick did not receive the relevant information by April 13,
2005,3 she would issue a notice of determination. As of April
18, 2005, petitioner had not provided the requested information.
On May 20, 2005, respondent mailed to petitioner the above-
mentioned Notice of Determination Concerning Collection Action(s)
3The letter actually stated the date as Apr. 13, 2004, which
was a typographical error as the letter was dated Mar. 30, 2005.
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Last modified: November 10, 2007