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an in-person hearing for February 16, 2005, and reprising the
points made in the previous letter. Petitioner neither appeared
for the hearing nor contacted the officer prior thereto. The
officer left a voicemail message for petitioner, who returned the
call and alleged that he did not receive the January 12, 2005,
letter. During that conversation petitioner also advised that he
was “living from hand to mouth and throws away receipts”. The
parties rescheduled a hearing for March 17, 2005.
On March 17, 2005, the settlement officer received a call
from petitioner, who said that he was still working on completing
financial information and unfiled returns. The settlement
officer explained that she was unable to afford additional time
and would be closing the case.
On March 24, 2005, respondent issued to petitioner the
aforementioned Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 sustaining the notice of
intent to levy. An attachment to the notice repeated the
prohibition on petitioner’s challenges to his underlying
liabilities, stated that petitioner did not raise any other
relevant issues or submit proposals regarding collection
alternatives, and noted that petitioner also had not filed income
tax returns for 1993 through 2003.
Petitioner filed an imperfect petition disputing the notice
on April 18, 2005, and an amended petition on June 8, 2005, both
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