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We further directed the parties to file status reports on or
before April 15, 2005.
Pursuant to the foregoing order, Ms. Carter on March 4,
2005, sent to petitioner a letter scheduling an appointment for
March 22, 2005, and requesting that petitioner advise her by
March 17, 2005, whether he preferred an in-person, telephone, or
correspondence conference and if he needed to reschedule. The
letter also asked that petitioner complete the Form 433-A to
enable consideration of any collection alternatives. Through a
series of facsimiles and phone calls, petitioner initially
requested that an in-person hearing be held on March 28 or 29,
2005, and then rescheduled the conference for March 30 via
telephone. Ms. Carter confirmed this understanding by a letter
dated March 28, 2005, and further stated:
You mentioned that you were unable to find any of your
Schedule C business receipts or statements and was
[sic] conceding this issue in full. You wish for this
office to continue the task of evaluating collection
alternatives.
As requested, I have enclosed Form 433-A Collection
Information Statement that you promised to complete and
facsimile back tomorrow. We also discussed how the IRS
has no record of you filing your income tax returns for
years 2001 and 2002 and the need for you to gather your
tax information so that you can file these delinquent
returns with this office. * * * If you are required to
file, you will be given 30 days to file your 2001
and/or 2002 tax returns with this office.
Another series of faxes from petitioner followed the above
letter. On March 30, 2005, he asked that the conference be held
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