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assigned to petitioner’s case (Appeals officer) scheduled peti-
tioner’s Appeals Office hearing. The Appeals officer was unable
to attend that scheduled hearing because of the death of the
Appeals officer’s father. Sometime thereafter, the Appeals
officer sent petitioner a letter rescheduling petitioner’s
Appeals Office hearing on a date and at a time not disclosed by
the record. Petitioner did not receive that letter until after
the rescheduled date and time for that hearing had passed.
Thereafter, at a time not disclosed by the record, petitioner had
an opportunity via the telephone to discuss with the Appeals
officer and/or the Appeals officer’s supervisor the notice of
intent to levy with respect to petitioner’s taxable years 1987
and 1990.
During petitioner’s communications with the Appeals Office,
petitioner claimed that he had made an overpayment with respect
to each of his taxable years 1984, 1985, and 1986 and that
respondent should have applied such claimed overpayments against
his unpaid liability for each of his taxable years 1987 and 1990.
Petitioner did not provide the Appeals Office with evidence to
verify any such claimed overpayments. During his communications
with the Appeals Office, petitioner did not offer any collection
alternatives, nor did he provide the Appeals Office with any
financial statements.
On May 24, 2000, respondent issued to petitioner a notice of
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