Fay B. Edwards - Page 5

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          and/or 6330 on June 19, 2003 (notice of determination).                     
          Respondent stated, in part:                                                 
               For years 1996 and 1997, statutory notices of                          
               deficiency were mailed to taxpayer at the appropriate                  
               address.  Accordingly, the underlying liability cannot                 
               be considered under CDP proceedings for these years.                   
               For tax years 1998, 2000, and 2001 the taxpayer did not                
               present evidence to substantiate her position that the                 
               underlying liability was not appropriate as assessed.                  
               The filing of the Notice of Federal Tax Lien is                        
               appropriate.  The liability is valid and outstanding.                  
               With respect to the proposed levy action for 2000 and 2001,            
          respondent issued a separate notice of determination on June 19,            
          2003.  Respondent sustained the proposed levy, stating in part:             
               Taxpayer did not present evidence to substantiate her                  
               position that the underlying liability was not                         
               appropriate as assessed.  The liability is valid and                   
               outstanding.                                                           
               Taxpayer did not propose any collection alternatives.                  
               Upon receiving the notices of determination, petitioner                
          filed a petition with this Court.  In addition, petitioner                  
          contacted respondent in an effort to arrange for a collection               
          alternative.  On June 26, 2003, petitioner sent respondent a                
          package of documents purporting to be an offer in compromise                
          (OIC).  Petitioner did not provide specific information regarding           
          her financial situation.  She explained generally that she had              
          limited resources and no relatives to help her, that she had lost           
          her employment, that she lived very modestly, and that she                  
          anticipated incurring significant medical and long-term care                





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