Drina L. McCorkle - Page 3




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               On August 30, 2001, petitioner signed a Form 433-A,                    
          Collection Information Statement for Individuals, and sent it to            
          respondent.                                                                 
               On September 6, 2001, petitioner submitted a Form 12153,               
          Request for a Collection Due Process Hearing, regarding her 1997            
          and 1999 tax years (hearing request).  Petitioner stated that she           
          disagreed with respondent’s decision to levy because she was                
          unable to pay the assessments in full at that time.  Petitioner,            
          however, did not dispute the amount of the liabilities.  She                
          requested that respondent consider an installment payment plan in           
          lieu of enforced collection action.                                         
               On January 23, 2002, petitioner sent respondent spreadsheets           
          showing the sales she closed and commissions she earned during              
          2001 and two pages of claimed business expenses.                            
               On the basis of all of the information provided by                     
          petitioner, respondent prepared a monthly income and expense                
          analysis.  Respondent concluded that petitioner had the ability             
          to pay $5,599 per month toward her outstanding 1997 and 1999 tax            
          liabilities.                                                                
               On March 19, 2002, respondent assigned Appeals Officer                 
          Denise Mountjoy to petitioner’s hearing request.  Appeals Officer           
          Mountjoy reviewed the administrative file and obtained                      
          transcripts of petitioner’s account for 1997 and 1999.  The                 
          administrative file and transcripts of account confirmed the                






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