- 9 - also received an earlier Notice of Levy against funds on deposit with Charles Schwab.” The letter is signed by Certified Public Accountant Stuart Douthett, with an address in Kansas. Enclosed with the letter was a Form 2848, authorizing Stuart Douthett and Harold Wolgast to represent petitioner. Respondent treated this letter as a request for an equivalent hearing with respect to the notice of levy and as a timely appeal from the notice of tax lien. Appeals Office Hearing On July 9, 2004, petitioner’s case was received in respondent’s Appeals Office in Wichita, Kansas. The case was initially assigned to Appeals Officer Dee Dugan. By letter dated July 14, 2004, and sent to the attention of Appeals Officer Dugan, Mr. Douthett stated that in August 1996 petitioner had filed a separate 1995 return and that in October 1996 “an amended return was filed (technically amending the return of Astrid M. Downing) to file a joint return.” Consequently, the letter asserted, “it appears that the statute of limitations should have expired prior to the first notification received by the taxpayer in 2001.” In addition, the letter asserted that petitioner had not been given proper credit for the $25,000 payment that he had included with his request for a filing extension with respect to his 1995 return. Appeals Officer Dugan began investigating this matter but retired before making any final determination. In an undatedPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007