Joseph Paul Freije - Page 10

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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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