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section 6330 hearing with petitioner. At the hearing, Appeals
Officer Cayenne explained the collection alternatives available
to petitioner. Petitioner indicated that he wanted respondent to
consider an offer-in-compromise. Appeals Officer Cayenne gave
petitioner the appropriate forms to file an offer-in-compromise.
Petitioner did not submit an offer-in-compromise.
Before issuing the notice of determination, Appeals Officer
Cayenne reviewed petitioner’s transcript of account for 1993 and
determined that respondent had sent petitioner his refund for
that year. After the section 6330 hearing, Appeals Officer
Cayenne sent petitioner transcripts of his account for 1987 and
1989. Appeals Officer Cayenne also submitted a request for
petitioner to be given credit for withholding for 1987 and 1989
that had not been credited to him.
On April 11, 2001, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) for 1987 and 1989
concluding that respondent could proceed with the proposed levy
action. The notice of determination stated that the levy should
reflect allowance of withholding credits of $2,346 for 1987 and
$278 for 1989, and that forms had been forwarded to effect this
change.
Withholding Credits and Abatement of Interest
On May 7, 2001, respondent mailed petitioner two notices--
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