William W. Howard - Page 3

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               On March 31, 1999, respondent mailed to petitioner a final             
          notice of intent to levy.  See sec. 6331.  The notice stated that           
          petitioner owed taxes, penalties, and interest totaling                     
          $329,918.45 and $147,568.72 for the taxable years 1987 and 1988,            
          respectively, and that respondent was preparing to collect these            
          amounts by levy.  The notice further stated that petitioner would           
          be given 30 days to request a hearing with respondent's Appeals             
               Petitioner timely filed a request for a hearing with                   
          respondent's Appeals Office.  On August 2, 1999, respondent's               
          Appeals Office issued to petitioner a Notice of Determination               
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          (the determination letter).  The determination letter stated that           
          because petitioner had been issued a notice of deficiency for               
          1987 and 1988 and had contested the notice in the Tax Court,                
          petitioner was not permitted to contest his liability for the               
          underlying taxes in the Appeals hearing.  The determination                 
          letter further stated that respondent would proceed with the                
          proposed collection action.                                                 
               On August 6, 1999, petitioner filed with the Court an                  
          imperfect petition for review of the determination letter,                  
          followed by an amended petition on September 20, 1999.                      
          Petitioner contends that the Appeals Office erred in failing to             

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