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asked for a face-to-face hearing and questioned whether the
Internal Revenue Service (the Service) “follows proper
procedure”, but petitioner raised no other issue regarding the
assessed liability or the Service’s intention to collect by levy.
On June 26, 2006, the settlement officer assigned to
petitioner’s case sent petitioner a letter acknowledging
petitioner’s request for a section 6330 hearing and scheduling a
telephone conference for August 1, 2006, “to discuss with me the
reasons you disagree with the collection action and/or to discuss
alternatives to the collection action.” The officer’s letter
also stated that if the time was not convenient or petitioner
preferred a face-to-face conference, petitioner should contact
the settlement officer within 14 days of the date of the letter.
In addition, the settlement officer requested that petitioner
submit certain information before his conference, including a
completed collection information statement and related
verification, signed tax returns for 2000, 2003, and 2005, and
proof of estimated tax payments for 2006.
By letter dated July 24, 2006, petitioner responded to the
June 26, 2006, letter. Among other things, petitioner complained
about the settlement officer’s setting a hearing date without
consulting with him, and he stated that he was not able to
participate in the August 1, 2006, telephone conference.
Petitioner also stated that he had requested a face-to-face
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Last modified: March 27, 2008