- 6 - petitioner's Appeals request as a claim for abatement,4 the Appeals Office denied it and advised petitioner that he could pursue the matter further by filing suit in the U.S. District Court or the U.S. Court of Federal Claims.5 The Appeals Office response was signed by Timothy I. Gukich as "Appeals Team Manager". On June 10, 2004, approximately 21 months after his request for a hearing under section 6330 and more than 13 months after denying his Appeals request, the Appeals Office sent a letter to petitioner offering him the opportunity to schedule a section 6330 hearing. In accordance with petitioner's request, a hearing was conducted via telephone by Settlement Officer Gwenda Dumas on August 31 and October 5, 2004. Petitioner was not allowed to raise challenges to the underlying tax liability during the hearing. Respondent thereupon sent petitioner a "Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330", with a Letter 3193 attached, dated October 15, 2004. The notice of determination was signed by Timothy I. Gukich, "Appeals Team Manager", and concluded that it would be 4 The parties have stipulated that petitioner did not file a Form 1040X, Amended U.S. Individual Income Tax Return, for 2000. 5 Insofar as the record discloses, petitioner did not file suit in either court. However, on Mar. 22, 2004, petitioner filed a petition for redetermination of a deficiency with this Court. Petitioner's case arising from that petition was dismissed for lack of jurisdiction on May 25, 2004.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007