Michael D. Keown and Rosann C. Keown - Page 5

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               in Letter LT-11, dated 11/08/2001, which was mailed                    
               certified to the taxpayers’ last known address.  The                   
               taxpayers responded with Form 12153, Request for a                     
               Collection Due Process Hearing, which was received                     
               12/05/2001.  The taxpayers’ appeal was timely.  The                    
               taxpayers are entitled to judicial review.  Appropri-                  
               ately, TC520/77 was input, staying collection.  This is                
               a levy issue only.  No Notice of Federal Tax Lien has                  
               been filed.                                                            
               The taxpayer appeared in person for his Collection Due                 
               Process hearing, his spouse chose to work instead of                   
               coming to the hearing.  Settlement Officer Mike Freitag                
               conducted the hearing and Settlement Officer Donna                     
               Fisher was also in attendance.                                         
               At the hearing the taxpayer was asked if he had any                    
               recording devices.  He said he did not have one and was                
               again reminded that no recording of Appeals hearings                   
               was allowed.                                                           
               Settlement Officer Mike Freitag has had no prior in-                   
               volvement with respect to these tax liabilities.                       
               Issues Raised by the Taxpayer                                          
               The taxpayer and his wife timely filed their joint                     
               income tax return for 1999, showing taxable earnings,                  
               attaching their W-2 forms and showing tax due on the                   
               return.  At the hearing the taxpayer was asked to point                
               out any irregularities in the making of the assessment.                
               He stated he couldn’t point out any irregularities and                 
               thought that the return was correct at the time of                     
               filing, but continued with his non-filer arguments.                    
               When the taxpayers were mailed Letter LT-11, Final                     
               Notice-Notice of Intent to Levy and Notice of Your                     
               Right to a Hearing, the taxpayers responded with Form                  
               12153, attaching several page [sic] of non-filer argu-                 
               At the hearing Appeals provided the following docu-                    
                    a)   A copy of the memorandum of 5/2/02 stating                   
                         audio and stenographic recordings of Appeals                 
                         cases will no longer be allowed;                             
                    b)   Copies of the forms 2866 to which the forms                  

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