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2004, in which he stated that petitioner’s arguments were without
merit, that petitioner had not filed the requested returns, and
that the settlement officer did not have petitioner’s phone
number or a power of attorney from Mr. Turner. The settlement
officer gave petitioner 10 days to contact him and provide
additional information regarding petitioner’s case.
On January 21, 2004, Mr. Turner submitted a power of
attorney and requested that the hearing be rescheduled. The
settlement officer rescheduled the hearing for January 26, 2004,
and a telephone hearing was held on that date. Neither
petitioner nor his representative provided the collection
information statement or the returns that the settlement officer
had requested, and they did not offer any information regarding
petitioner’s plans to pay the liabilities at the hearing. Mr.
Turner asked for additional time to submit the information, and
the settlement officer gave him until the end of the day to do so
or the settlement officer would sustain the lien and close the
hearing.
On January 27, 2004, Mr. Turner sent a fax to the settlement
officer that contained a declaration signed by petitioner. The
declaration stated that petitioner had not received the notices
of assessment.
On January 29, 2004, respondent mailed to petitioner a
Notice of Determination Concerning Collection Action(s) Under
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Last modified: March 27, 2008