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discretion in proceeding with a proposed levy on petitioner’s
assets.
Background
At the time of the filing of the petition in this case,
petitioner resided in Washington, D.C. At all relevant times,
petitioner had outstanding income tax liabilities for taxable
years 1990, 1991, 1992, 1993, 1995, 1999, and 2000 (collectively,
petitioner’s unpaid tax liability). On July 20, 2002, respondent
sent petitioner a Final Notice - Notice of Intent to Levy and
Notice of your Right to a Hearing (levy notice) with respect to
petitioner’s unpaid tax liability. In response, on August 15,
2002, petitioner timely filed a Request for a Collection Due
Process Hearing (request) for taxable years 1990, 1991, 1992,
1993, 1995, 1999, and 2000.
The request consisted, in its entirety, of the following:
I do not understand the Account Summary page total
please explain to me what is going on [sic]
Assessed Balance, Statutory Additions, Total, how did
you come up with that balance. [sic] I would like to
make monthly payment that I can aford. [sic] I do
realize that it may take me the rest of my life to pay.
How do I start paying and were. [sic] Please contact me
by mail or phone * * * HELP
Between September 18, 2003, and July 13, 2004, petitioner
and respondent’s Appeals officer engaged in telephonic
conversations and exchanged correspondence. Petitioner and the
Appeals officer discussed collection alternatives, including an
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