Fletcher H. Hyler - Page 10

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               On April 19, 2000, Rosado wrote to Stone.  His letter noted            
          that he and Stone had discussed a monthly payment plan for                  
          petitioner’s 1993 income tax liability and asked for copies of a            
          number of documents relating to petitioner’s financial status.              
          The letter further indicated that Rosado had enclosed transcripts           
          of petitioner’s income tax accounts for 1993, 1995, and 1997, as            
          well as IRS publications relating to preparation of financial               
          statements, to the IRS collection process, and to "Your Rights as           
          a Taxpayer".  The letter concluded as follows:                              
               5.   Notice of Federal Tax Lien.  Per our conversation,                
                    I will delay Filing Notice of Federal Tax Lien                    
                    until May 15, 2000.  At that time I will re-                      
                    evaluate the need for filing.  We had discussed                   
                    alternatives to filing a Notice of Lien such as                   
                    the posting of a bond.  I would expect your                       
                    proposal on this matter no later than 5/15/2000.                  
               6.   You had indicated that notice of assessment for                   
                    1995 and 1997 was not received.  Is this correct?                 
               7.   For your information I have requested the                         
                    administrative case file for 1995 and 1997, so                    
                    that any issues can be addressed.  As soon as I                   
                    receive these files, I will share it with you.  I                 
                    also agreed to delay filing Notice of Federal Tax                 
                    Lien for these periods until we can address the                   
                    assessments.  If there are no unresolved issues                   
                    regarding assessments, then collection of the                     
                    balance due will be addressed.  Will also address                 
                    filing of Notice of Federal Tax Lien.                             
               8.   During the interim, please advise Mr. Hyler that                  
                    he can begin sending payments of $5000 to my                      
                    office.  Please note that penalties and interest                  
                    continue to accrue on any unpaid balance.  This is                
                    not an acceptance of a monthly payment proposal.                  
                    That will be determined at a later time.                          

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