Gary James Copeland - Page 6




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               6212 and 6213, since I have not been able to locate                    
               them.                                                                  
                    Without your furnishing me with these documents                   
               and information, I will be unable to “ascertain” * * *                 
               whether the individual who sent me the Deficiency                      
               Notice was authorized to do so, and whether I am le-                   
               gally required to take any notice of it. * * *                         
               [Reproduced literally.]                                                
               On January 8, 2001, respondent assessed petitioner’s tax, as           
          well as any penalties and interest as provided by law, for each             
          of his taxable years 1997 and 1998.  (We shall refer to those               
          assessed amounts, as well as interest as provided by law accrued            
          after January 8, 2001, as petitioner’s unpaid liabilities for               
          1997 and 1998.)                                                             
               On January 8, 2001, respondent issued to petitioner a notice           
          of balance due with respect to petitioner’s unpaid liabilities              
          for 1997 and 1998.                                                          
               On August 14, 2001, respondent issued to petitioner a final            
          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to his taxable years 1997           
          and 1998.  On or about September 10, 2001, in response to the               
          notice of intent to levy, petitioner filed Form 12153, Request              
          for a Collection Due Process Hearing (Form 12153), and requested            
          a hearing with respondent’s Appeals Office (Appeals Office).                
          Petitioner attached a document to his Form 12153.  That document            
          stated in pertinent part:                                                   
                    I am requesting a “Due Process Hearing” as out-                   
               lined in From 12153.  I am “challenging the appropri-                  





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