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On May 24, 2005, petitioner contacted Ms. Chadwell and
requested a face-to-face hearing. That same day, Ms. Chadwell
sent petitioner a letter to confirm the date, time, and location
of the section 6330 hearing, which was scheduled for June 23,
2005. Ms. Chadwell again asked petitioner to submit a completed
Form 433-A and bring her 2004 tax return to the section 6330
hearing.
On June 21, 2005, petitioner left Ms. Chadwell a voice
message that petitioner could not keep the scheduled appointment
due to a change in her work schedule.
On June 22, 2005, Ms. Chadwell called petitioner, and
petitioner stated that she wished to reschedule the hearing for
June 29, 2005. Ms. Chadwell told petitioner that this was
petitioner’s last chance for a face-to-face hearing. That same
day, Ms. Chadwell sent petitioner a letter rescheduling the
hearing for June 29, 2005, advising petitioner this was
petitioner’s last chance for an in-person hearing, and stating
that petitioner could have a telephone hearing and/or submit
documents for Ms. Chadwell to consider (i.e., a correspondence
hearing).
On June 29, 2005, petitioner called Ms. Chadwell and advised
her that she (petitioner) could not make the scheduled hearing.
Ms. Chadwell told petitioner that she would not be offered
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Last modified: May 25, 2011