Thomas C. Johnson - Page 4

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          Daniel L. Shirah (Mr. Shirah) thereafter sent petitioner a letter           
          dated October 3, 2001, scheduling the requested conference.                 
               A telephone conference between petitioner and Mr. Shirah was           
          conducted on October 19, 2001.  During the conference there                 
          ensued some discussion of collection alternatives, among other              
          things, and after the conference Mr. Shirah sent to petitioner              
          for his completion Form 656, Offer in Compromise, and Form 433-A,           
          Collection Information Statement for Wage Earners and Self-                 
          Employed Individuals.  Petitioner began filling out the documents           
          but never submitted completed forms to respondent.                          
               On January 10, 2002, respondent issued to petitioner the               
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 sustaining proposed collection action.3            
          Petitioner on February 5, 2002, filed with the Tax Court an                 
          imperfect petition challenging the notice.  The petition                    
          reflected that petitioner wished to have his case heard for two             
          reasons; i.e., he was experiencing hardship due to the disability           
          of end stage renal disease, and he had now found proof that his             
          liability was too great.                                                    
               Petitioner then filed an amended petition on March 6, 2002,            
          consisting of 11 handwritten pages explaining his circumstances.            
          He indicated therein that the tax years involved were 1995                  


               3 We note that the notice of determination refers in                   
          apparent error to “levy”, rather than “lien”, action.                       




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