Michael Stein - Page 12

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               In the attached memorandum, petitioner asserted he would               
          complete his delinquent returns within 60-90 days to prove that             
          he did not owe the tax liabilities determined by respondent.                
               In the attached memorandum, petitioner also stated he was              
          appealing Revenue Officer Angotta’s “levy warning letter” dated             
          February 14, 2000, which, according to petitioner, stated:                  
          “Enforced collection may include placing a levy on your bank                
          accounts, wages, receivables, commissions, etc.”6  In the                   
          attached memorandum, petitioner asserted:  “Mr Angotta informed             
          me over the telephone that I have until March 15, 2000 to appeal            
          this action.”                                                               
               In the attached memorandum, petitioner also said Revenue               
          Officer Angotta failed to respond to petitioner’s messages left             
          on Revenue Officer Angotta’s answering machine before February              
          11, 2000, in which petitioner stated that he was ready to                   
          personally meet with Revenue Officer Angotta to hand in his                 
          appeal.                                                                     
               In a letter dated June 22, 2000, Appeals Officer William A.            
          Hirsch (Appeals Officer Hirsch) informed petitioner that                    
          respondent’s NFTL had been assigned to him for consideration.               
          After repeated failed attempts by Appeals Officer Hirsch and                
          petitioner to get in touch with each other, Appeals Officer                 
          Hirsch, in a letter dated July 26, 2000, informed petitioner that           

               6The Feb. 14, 2000, letter was not part of the record.                 





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