Merry J. Chandler - Page 5

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          Besides the entry on October 12, 2001, no entry in the case                 
          activity record references any discussion of a personal                     
               On February 19, 2002, Appeals issued to petitioner the                 
          I.  Introduction                                                            
               If any person liable for Federal tax liability neglects or             
          refuses to make payment within 10 days of notice and demand, the            
          Commissioner is authorized to collect the tax by levy on that               
          person’s property.  See sec. 6331(a).  As a general rule, at                
          least 30 days before taking such action, the Commissioner must              
          provide the person with a written final notice of intent to levy            
          that describes, among other things, the administrative appeals              
          available to the person.  See sec. 6331(d).                                 
               Upon request, the person is entitled to an administrative              
          review hearing before Appeals (a collection due process hearing).           
          Sec. 6330(b)(1).  Appeals must offer the person an opportunity              
          for a hearing, in person, at the Appeals Office closest to the              
          person’s residence.  See sec. 301.6330-1(d)(2), Q&A-D7, Proced. &           
          Admin. Regs.  Nevertheless, a collection due process hearing                
          “may, but is not required to, consist of a face-to-face meeting,            
          one or more written or oral communications between an Appeals               
          officer or employee and the taxpayer * * *, or some combination             

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