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Petitioner was informed that unless he had other issues to raise,
the Appeals officer would not meet with him for a face-to-face
hearing. The Appeals officer then tried to schedule a telephone
hearing with petitioner twice, one for November 24, 2003, and the
other for December 5, 2003. Petitioner notified the Appeals
officer in writing that he refused to participate in a telephone
hearing.
Petitioner then requested a hearing through correspondence,
and provided the Appeals officer with some additional
documentation. Petitioner did not raise any spousal defenses,
offer any other challenges to the collection action, or suggest
any collection alternatives. After reviewing all information
that was submitted by petitioner, on February 9, 2004, the
Appeals officer issued a Notice of Determination Concerning
Collection Action(s) under Section 6320 and/or 6330 that stated
that the Internal Revenue Service has complied with Code and
procedural requirements, that no relief would be granted, and the
proposed levy was sustained. Petitioner then timely filed a
petition with this Court.
The only issue petitioner asserts is that he is entitled to
a face-to-face collection due process hearing. Respondent argues
3(...continued)
need to refute these arguments with somber reasoning and copious
citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984).
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