Roger L. Sherer - Page 5

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          12153, Request for Collection Due Process Hearing.  In his Form             
          12153, petitioner contested only the tax liability.                         
               On January 29, 2004, respondent mailed to petitioner a                 
          letter advising him that his Form 12153 had been received and               
          that his request for a hearing was being processed.  Petitioner             
          was further advised in this letter that he had not filed income             
          tax returns for the taxable years 1998, 1999, 2000, 2001, and               
          2002, and he was instructed to file said returns by February 12,            
          2004.  He was further instructed that if he failed to file the              
          returns, the matter would be forwarded to respondent’s Appeals              
          Office for consideration of his request for a hearing.                      
          Petitioner has acknowledged that he received the January 29,                
          2004, letter.  Petitioner failed to file, as of the date of                 
          trial, any income tax returns for the taxable years 1998 through            
          2002.                                                                       
               In an April 14, 2004, letter, the Appeals officer advised              
          petitioner to contact her and schedule a hearing.  She also                 
          advised petitioner that he should provide her with all                      
          information he had in support of his position that his underlying           
          tax liability was in error, and that she could not offer him a              
          collection alternative in satisfaction of his tax liability for             
          1999 because he continued to fail to file his income tax returns.           
               On May 24, 2004, petitioner mailed to the Appeals officer a            
          copy of a Form 1099-MISC, Miscellaneous Income, issued to                   






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