- 4 - 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 anyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007