Lionel Brown - Page 5

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          1995.  She could not consider the 1998 and 1999 years because               
          petitioner had previously received a hearing for those years in             
          September 2001.                                                             
               During the hearing, petitioner also requested that Ms.                 
          Spaulding consider collection alternatives to the proposed levy.            
          They discussed an installment agreement, but petitioner said he             
          could not afford the payments because he had been suspended from            
          his teaching position and was unemployed at the time.  Ms.                  
          Spaulding also discussed an offer in compromise, but petitioner             
          said he did not believe that it was a viable option because                 
          several offers he had submitted in the past had been rejected and           
          he did not have the funds to submit another offer in compromise.            
               The final option Ms. Spaulding discussed with petitioner was           
          placing his account in “currently not collectible” status.  In              
          order to facilitate this classification, Ms. Spaulding asked                
          petitioner to complete and submit a Form 433-A, Collection                  
          Information Statement for Wage Earners and Self-Employed                    
          Individuals.  She also requested a statement from his employer              
          that he was not currently working for them and bank statements to           
          verify his income.                                                          
               On at least four separate occasions, Ms. Spaulding requested           
          that petitioner complete and submit the forms.  Petitioner did              
          not submit the completed documentation.                                     







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