Deborah Carman Goodin - Page 3

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          respect to the notice of deficiency relating to her taxable years           
          1997, 1998, and 1999.                                                       
               On July 8, 2002, respondent assessed petitioner’s tax, as              
          well as additions to tax and interest as provided by law, for               
          each of her taxable years 1997, 1998, and 1999.  (We shall refer            
          to those unpaid assessed amounts, as well as interest as provided           
          by law accrued after July 8, 2002, as petitioner’s unpaid liabil-           
          ities for 1997, 1998, and 1999.)                                            
               Respondent issued to petitioner the notice and demand for              
          payment as required by section 6303(a) with respect to peti-                
          tioner’s unpaid liabilities for 1997, 1998, and 1999.                       
               On March 24, 2003, respondent issued to petitioner a notice            
          of Federal tax lien filing and your right to a hearing (notice of           
          tax lien) with respect to petitioner’s unpaid liabilities for               
          1997, 1998, and 1999.                                                       
               On or about April 6, 2003, in response to the notice of tax            
          lien, petitioner filed Form 12153, Request for a Collection Due             
          Process Hearing (Form 12153), and requested a hearing with                  
          respondent’s Appeals Office (Appeals Office).  The following is             
          the only explanation that petitioner provided in her Form 12153             
          for her disagreement with respondent’s proposed collection                  
          action:  “Mathmaticly [sic] incorrect”.                                     
               On a date not disclosed by the record, a settlement officer            
          with the Appeals Office (settlement officer) held a telephonic              

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