Ginger Harmornick - Page 5

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          assessed the determined deficiencies and additions to tax for               
          1991, 1992, and 1993, as well as statutory interest.  On that               
          same day, respondent sent petitioner notices of balance due,                
          informing petitioner that she had liabilities for 1991, 1992, and           
          1993, and requesting that she pay them.  Petitioner failed to do            
               D.  Respondent’s Final Notice and Petitioner’s Response                
               On October 25, 1999, respondent sent petitioner a Final                
          Notice-–Notice of Intent to Levy and Notice of Your Right to a              
          Hearing (the Final Notice).  The Final Notice was issued in                 
          respect of petitioner’s outstanding liabilities for 1990 through            
               On November 23, 1999, petitioner submitted to respondent               
          Form 12153, Request for a Collection Due Process Hearing.                   
          Petitioner’s request stated in pertinent part:  “The basis of my            
          complaint is what I believe to be the lack of a valid summary               
          record of assessment pursuant to 26 CFR �301.6203-1.”                       
               E.  The Administrative Hearing                                         
               On June 22, 2000, Veronica Lindersmith of respondent’s                 
          Appeals Office in Las Vegas, Nevada, conducted an administrative            
          hearing by way of a telephone conference with petitioner’s                  
          representative, Thomas W. Roberts.2  By letter dated August 8,              

               2  The conference was conducted by telephone in order to               
          accommodate Mr. Roberts, whose office was located out of state.             

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