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On or about April 30, 2001, an Appeals officer of respondent
sent petitioner a letter advising him that a conference would be
scheduled in the future. In May 2001, petitioner advised the
Appeals officer that he did not wish to appear in person in
respondent's office to attend a face-to-face meeting in
connection with a hearing.
On June 4, 2001, petitioner and the Appeals officer
discussed petitioner's request by telephone. During that
conversation, petitioner advised the Appeals officer that he
would be willing to "pay 25 cents per year for 1997, 1998, and
1999, call it even, and then start afresh with the year 2001."
The Appeals officer advised petitioner that this proposed
collection alternative to the levy was not acceptable. Later
that day, petitioner left voice-mail messages for the Appeals
officer seeking information concerning changes respondent made to
his 1995, 1996, 1997, and 1998 returns that resulted in
additional tax, additions to tax, and interest for those years as
well as information concerning why payments intended for one year
had been applied to other years. Petitioner further advised the
Appeals officer that his problems began with his 1995 taxes. In
addition, petitioner advised the Appeals officer of petitioner's
claim that respondent had altered petitioner's check for $1,776
(intended as payment of his 1997 taxes) so that it was posted for
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