Richard John Florance, Jr. - Page 3

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               On March 10, 2003, respondent sent petitioner a Notice of              
          Federal Tax Lien Filing and Your Right to a Hearing Under IRC               
          6320 regarding petitioner’s 1994, 1995, and 1996 tax years.                 
               On March 14, 2003, petitioner sent respondent a Form 12153,            
          Request for a Collection Due Process Hearing, regarding his 1994,           
          1995, and 1996 tax years.2  In a 22-page attachment to the Form             
          12153, petitioner essentially challenged his underlying tax                 
               On July 10, 2003, petitioner mailed respondent three Forms             
          1041, U.S. Income Tax Return for Estates and Trusts, and Forms              
          W-2, Wage and Tax Statement, for 1994, 1995, and 1996.                      
               On September 3, 2003, a face-to-face hearing was held with             
          petitioner, Appeals Officer Nancy J. Driver, and Appeals                    
          Collection Specialist Veronica Smith.  Appeals Officer Driver               
          confirmed that respondent had complied with all applicable laws             
          and administrative procedures regarding 1994, 1995, and 1996, and           
          she reviewed the administrative file for those years.  Petitioner           
          did not propose any collection alternatives at the hearing and              
          stated he was not interested in discussing collection                       
          alternatives because he did not believe he owed the amounts in              

               2  On the face of the Form 12153, petitioner listed 1994 and           
          1995 as the taxable periods.  In his 22-page attachment to the              
          Form 12153, petitioner referenced 1996.  Additionally, on Apr. 9,           
          2003, petitioner filed a second Form 12153 on which he listed               
          1996 as the taxable period.  Respondent does not dispute that               
          petitioner timely requested hearings to challenge all 3 years.              

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