Michael Stein - Page 10

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          Appeals Office issued petitioner a decision letter upholding the            
          proposed levy.                                                              
               In a letter dated October 22, 1999, Revenue Officer Mele               
          informed petitioner that respondent would begin levying on his              
          income sources and assets on November 5, 1999.                              
               On or about November 8, 1999, petitioner submitted a Form              
          9423, Collection Appeal Request, in which he attributed the                 
          delays in filing his returns to respondent’s failure to follow              
          through on petitioner’s request for capital loss carryover                  
          information from 1987 that he needed to file his returns for the            
          tax years at issue.  Petitioner’s Form 9423 states that Revenue             
          Officer Mele was unable to obtain petitioner’s 1987 return.                 
               On or about December 7, 1999, petitioner submitted to                  
          Revenue Officer Mele a request to enter into an installment                 
          agreement to pay his tax liabilities for 1992 through 1994.  On             
          January 11, 2000, Revenue Officer Mele sent a letter to                     
          petitioner’s post office box address denying petitioner’s request           
          for an installment agreement because petitioner had not filed               
          income tax returns for 1992 through 1999.  The January 11, 2000,            
          letter specifically instructed petitioner to send an appeal                 
          request to Revenue Officer Mele at his office address on or                 
          before February 11, 2000, if petitioner wished to appeal the                
          denial of his installment agreement request.  Petitioner did not            
          appeal the denial of his installment agreement request.                     






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