Clifford W. Miller - Page 5

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            petitioner notified of that request and respondent’s                                       
            consideration thereof or given an opportunity to participate in                            
            any of the administrative proceedings relating thereto.                                    
                  Sometime after January 19, 1999, respondent notified peti-                           
            tioner of his right to a hearing (Appeals Office hearing) at                               
            which he would be able to contest a proposed collection action                             
            against him with respect to the unpaid portion of the assessed                             
            1990 tax deficiency.                                                                       
                  On May 24, 1999, after the North-South Carolina Appeals                              
            Office of the Internal Revenue Service (Appeals Office) held the                           
            Appeals Office hearing that petitioner had requested, the Appeals                          
            Office issued to petitioner a “NOTICE OF DETERMINATION CONCERNING                          
            COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of                            
            determination).  The notice of determination contained the                                 
            following summary of the matters that were considered at peti-                             
            tioner’s Appeals Office hearing:                                                           
                  Matters Considered                                                                   
                  The requirements of law and administrative procedures:                               
                  whether the Service met its statutory and administra-                                
                  tive requirements prior to levy.                                                     
                  The relevant issues: whether Mr. Miller’s claim for                                  
                  “innocent spouse” relief could now be considered.                                    
                  The intrusiveness of the collection action or the                                    
                  proposed collection action: whether Mr. Miller’s situa-                              
                  tion warranted forbearance of the collection action                                  
                  until his claim could be considered.                                                 
            The matter considered by the Appeals Office relating to “Mr.                               

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