Thomas Lou Harris - Page 2

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               Thomas Lou Harris resided in Mount Vernon, Washington, when            
          he filed his petition.  The assessments relate to his 1987, 1988,           
          1989, 1990, 1991, 1992, and 1993 Federal income tax liabilities             
          (i.e., years in which petitioner did not file returns).  On                 
          September 11, 1998, respondent issued petitioner notices of                 
          deficiency relating to the years in issue.  Petitioner received,            
          but did not seek redetermination of, the notices of deficiency.             
               On October 13, 1999, respondent sent petitioner a Notice of            
          Intent to Levy and Notice of Your Right to a Hearing.  On October           
          27, 1999, petitioner filed a request for a Collection Due Process           
          Hearing (i.e., Form 12153) stating that “No summary assessment              
          has been provided as requested.”                                            
               In a letter dated June 29, 2000, respondent’s Appeals                  
          officer scheduled petitioner’s hearing for July 14, 2000, at 8:30           
          a.m. and provided petitioner with the option of a face-to-face or           
          a telephone hearing.  The letter also stated that petitioner had            
          been provided with a copy of computer transcripts that identified           
          the record of assessment and included data “identifying the tax             
          periods, the taxpayer, taxable activities, list of tax owed as              
          [it] appears on [the] record of assessment, and certifying                  
          officer.”  Petitioner did not appear at the hearing or call the             
          Appeals officer.                                                            

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