John J. Delgado - Page 3

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               On February 4, 2004, respondent sent petitioner a final                
          notice--notice of intent to levy and notice of your right to a              
          hearing regarding petitioner’s 1998, 1999, and 2000 tax years               
          (notice of levy).                                                           
               On or about March 7, 2004, respondent received a Form 12153,           
          Request for a Collection Due Process Hearing, regarding                     
          petitioner’s 1998, 1999, and 2000 tax years (hearing request).              
          The hearing request was postmarked February 27, 2004, and                   
          respondent treated it as received timely.  In the hearing                   
          request, petitioner checked the box for notice of levy/seizure              
          and in the space to explain why he did not agree he wrote:  “Not            
               On June 15, 2004, Settlement Officer J. Feist, from                    
          respondent’s Tampa Appeals Office, mailed petitioner a letter               
          that scheduled a section 6330 hearing for June 24, 2004.                    
          Settlement Officer Feist gave petitioner transcripts of his                 
          account for the years in issue and offered petitioner an                    
          opportunity for a face-to-face section 6330 hearing.  In light of           
          the fact that petitioner raised frivolous arguments in the past,            
          however, Settlement Officer Feist instructed petitioner to write            
          by June 22, 2004, specific relevant issues before he would grant            
          a face-to-face section 6330 hearing.  At that time, Settlement              
          Officer Feist also provided petitioner with a document entitled             
          “The Truth About Frivolous Tax Arguments” and a link to an IRS              

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