Scott Perry Picchiottino - Page 5

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          You still owe the balance due and penalty and interest will                 
          continue to accrue until the balance due has been paid in full,             
          but we are not enforcing collection until you are able to make              
          payments on the balance due at some point in the future.”                   
               Thereafter, the case was assigned to the IRS Office of                 
          Appeals in Phoenix, Arizona.  Settlement Officer Thomas L. Tracy            
          (Mr. Tracy) sent petitioner and Ms. Picchiottino a letter dated             
          November 5, 2003, scheduling a hearing for November 25, 2003, and           
          briefly outlining the hearing process.  Petitioner and                      
          Ms. Picchiottino then submitted another Form 12153 with respect             
          to all 4 years dated November 7, 2003, and received by the IRS on           
          November 13, 2003.  They checked the box indicating disagreement            
          with a filed notice of Federal tax lien and wrote:  “Request                
          without predjudice [sic] that hearing be held after Superior                
          Court Action FN 2003-092649 is adjudicated.”                                
               Mr. Tracy responded by a letter to petitioner dated November           
          13, 2003, stating:                                                          
               I am in receipt of Form 12153 signed by you and Kathryn                
               Picchiottino on November 7, 2003.  It states only that                 
               you wish a hearing after Superior Court Action FN 2003-                
               092649 is adjudicated.  I understand that this is your                 
               divorce suit.  I am sorry, but I cannot defer action on                
               your case for an extended and indefinite period of                     
               time.                                                                  
               We mutually scheduled the November 25 hearing and if                   
               that date is inconvenient, I will gladly reschedule to                 
               accommodate you.  If we cannot schedule and hold a                     
               hearing by December 10, 2003, I will make my                           
               determination from information in the file and with no                 
               further hearing opportunity.                                           





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