Jan Lister - Page 5

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               By letter dated April 5, 2002, Appeals Officer Brenda J.               
          Dodson advised petitioner that she had been assigned petitioner’s           
          case, and she explained the objective of a hearing under section            
          6330.  Ms. Dodson also stated the following with respect to                 
          petitioner’s explanation of her disagreement with the proposed              
          collection action set forth in Form 12153:                                  
               Based on your statement on the Form 12153, you are                     
               disputing the proposed levy action and that you had any                
               taxable income for the periods in question.  Based upon                
               my review of the case administrative file and reviewing                
               a transcript of the account in question it indicates                   
               assessments and balances due for the tax periods ending                
               December 31, 1993 and December 31, 1994.  You were                     
               afforded the opportunity to dispute the tax assessments                
               upon issuance of the Notice of Deficiency.  This notice                
               afforded you 90 days to petition the United States Tax                 
               Court to contest the proposed tax determination.  You                  
               did not exercise this right, prompting a default                       
               resulting in the assessments.  Since you did not                       
               petition the United States Tax Court during this 90-day                
               period you are not entitled to any further hearing                     
               relating to the amount of the liability for the 1993 or                
               1994 year under the Collection Due Process Hearing                     
          Ms. Dodson also advised petitioner of collection alternatives but           
          pointed out that two of those alternatives, an installment                  
          agreement and the offer in compromise, required that the                    
          taxpayer’s filing obligations be current.  Ms. Dodson emphasized            
          that petitioner had not filed Federal income tax returns for any            
          of the years 1995 through 2000.  She advised petitioner that                
          before the Service could evaluate any collection alternative,               
          petitioner must submit current financial information, must                  
          indicate the monthly installment payment petitioner believed she            

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