W. James Kubon - Page 3

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          verification from the Secretary that the requirements of any                
          applicable law or procedure had been met.                                   
               On September 12, 2003, respondent sent petitioner a letter             
          to request that petitioner complete a Form 433A, Collection                 
          Information Statement for Individuals, to assist in considering             
          collection alternatives.  Petitioner did not complete and return            
          the Form 433A to respondent.                                                
               On October 6, 2003, respondent sent petitioner a letter                
          outlining respondent’s policy at the time of not granting face-             
          to-face hearings to individuals raising only frivolous arguments.           
          A telephonic interview was offered and scheduled for November 5,            
          2003.  On October 22, 2003, petitioner responded to the October             
          6, 2003, letter by stating:  “to summarize your position you are            
          NOT going to allow me to have a hearing that I can record and you           
          will NOT permit me to bring up relevant issues that I covered in            
          my CDP request”.  Petitioner refused to participate in a                    
          telephonic interview with respondent.                                       
               On December 31, 2003, respondent issued to petitioner a                
          Notice of Determination Concerning Collection Action(s) Under               
          Section 6320 and/or 6330 (notice of determination) with regard to           
          1999.  The notice of determination stated:                                  
                    Appeals considered whether the collection action taken            
               or proposed balances the need for the efficient collection             
               of the taxes with the legitimate concern of the taxpayer               
               that any collection action be no more intrusive than                   
               necessary.  We find that enforced collection action is not             
               more intrusive than necessary because the Automated                    





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