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$1,046.90 for his 1993 tax year. The check represented
petitioner’s refund for 1993 of $971.78 and $75.12 in interest.
Section 6330 Proceedings
On May 10, 2000, respondent sent petitioner a Final Notice,
Notice of Intent to Levy and Notice of Your Right to a Hearing
(levy notice) with respect to petitioner’s 1987 and 1989 taxable
years.
On June 8, 2000, petitioner filed a Form 12153, Request for
a Collection Due Process Hearing for 1987 and 1989 (hearing
request). Petitioner attached a two-page letter to the hearing
request explaining his disagreement with the levy notice. In the
two-page letter, petitioner stated, among other things: (1) That
the “IRS inordinately delayed billing me for years, thereby
drastically increasing the amount owed”, (2) the “IRS sent what
it admitted to be a wrong bill” and “then sent an amended bill
which was itself apparently wrong”, (3) for 10 years “the IRS
failed to respond to my timely request for an installment plan”,
(4) “I experienced a delay of well over 30 days and often months
and years to resolve specific issues”, (5) “the IRS failed to
respond to my request for information about the amount owed,
about installment payment procedures, about abatement”, and (6)
“the IRS made numerous errors and delays”. Petitioner also
requested an offer-in-compromise.
On December 20, 2000, Appeals Officer Phyllis Cayenne held a
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