Leonard O. Parker, Jr. - Page 6

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          to Magee stating that he was unable to attend or adequately                 
          prepare for the conference in Jackson, and that Magee’s deadline            
          for sending affidavits and documents in advance of the conference           
          had already passed.  He stated that he “will be available for the           
          conference via telephone”, but he did not waive his right under             
          section 301.6320-1(d)(2), Q&A-D7, Proced. & Admin. Regs., to have           
          a hearing at respondent’s office.                                           
          D.   The March 27, 2002, Telephone Call and Events Leading to               
               Respondent’s Determination                                             
               Petitioner and Magee spoke by telephone on March 27, 2002.             
          During the telephone call, petitioner said, inter alia, that the            
          notice of Federal tax lien had been filed prematurely and that              
          the Taxpayer Advocate’s Office had placed a hold on collection              
               Petitioner wrote letters and sent faxes to Magee and other             
          employees of respondent between March 27 and May 2, 2002.                   
          Petitioner asked that respondent provide him with copies of                 
          respondent’s records relating to his offers in compromise,                  
          requests for abatement of interest and penalties, and requests              
          for assistance from the Taxpayer Advocate’s Office, and he told             
          Magee that the amount that respondent sought to collect for 1992-           
          94 was incorrect because respondent had not applied a credit from           
          a later year to those years.                                                

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