Alan L. Poe - Page 5

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          taxable year 1999.  At that hearing, the settlement officer also            
          gave petitioner a copy of Pierson v. Commissioner, 115 T.C. 576             
          (2000), and explained the warning of the Court in that Opinion              
          with respect to section 6673(a)(1).                                         
               On November 4, 2003, the Appeals Office issued to petitioner           
          a notice of determination concerning collection action(s) under             
          section 6320 and/or 6330 (notice of determination).  That notice            
          of determination stated in pertinent part:                                  
               Summary of Determination                                               
               Appeals determination is that Compliance is upheld.  No                
               relief is granted.  You were given an opportunity to                   
               prepare and file corrected returns and provide a com-                  
               pleted Collection Information Statement.  You failed to                
               file corrected returns.  You did not provide any finan-                
               cial information on which consideration of alternatives                
               could be based.  You raised only frivolous arguments                   
               and were given a copy of Pierson v. Commissioner.                      
          An attachment to that notice of determination stated in pertinent           
                             SUMMARY AND RECOMMENDATION                               
               You requested a Collection Due Process (CDP) Hearing                   
               with Appeals under the provisions of IRC �6330.                        
                    -The determination of Appeals is that the proposed                
                    collection actions are appropriate and are upheld.                
                    No relief is granted.                                             
                  *       *       *       *       *       *       *                   
               The statute of limitations has been suspended since                    
               12/09/2002.  The Settlement Officer had no involvement                 
               in your case prior to the assignment for the CDP Hear-                 

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