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Goldammer), on October 25, 2004. In the letter, Mr. Callanan
scheduled a CDP hearing by telephone on November 15, 2004, and
also offered Mr. Goldammer an opportunity to have either a face-
to-face conference or a hearing by correspondence. The November
15, 2004, hearing was continued until December 16, 2004.
Petitioner requested a face-to-face conference, which was
held on December 16, 2004, with petitioner, Mr. Callanan, and Mr.
Goldammer in attendance. A second face-to-face conference
occurred between Mr. Callanan and Mr. Goldammer on February 4,
2005.
At the December 16, 2004, conference, petitioner
acknowledged that he had received the notice of deficiency but
had relied on his representative at that time to file a petition
with the Court. Petitioner acknowledged that it was his
responsibility to assure that a petition was filed with this
Court and that he had failed in this duty. After this admission,
Mr. Callanan explained to petitioner that because he had received
a notice of deficiency, the merits of the underlying deficiencies
could not be raised as part of the CDP hearing. The parties then
discussed the appropriateness of the collection action, the
filing of the Notice of Federal Tax Lien, and possible collection
alternatives.
With respect to the collection alternatives discussed at the
December 16, 2004, CDP hearing, petitioner requested that any
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