Bradley W. Bean - Page 6

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          informed petitioner that if he did not participate, a                       
          determination would be made on the basis of the administrative              
          record.  Petitioner did not participate in the telephone                    
          conference and made no attempt to reschedule.                               
               On October 20, 2004, respondent sent petitioner a letter               
          advising him that a determination would be made by November 12,             
          2004.  Respondent requested that petitioner submit any additional           
          documentation that he wished considered in making the                       
          determination.                                                              
               Petitioner sent respondent a letter on October 27, 2004,               
          again requesting a face-to-face hearing.  Petitioner stated that            
          a telephone conference was unacceptable because “Documents cannot           
          be produced over the telephone, nor can an accurate record of               
          such a meeting.”  Petitioner did not raise any additional                   
          arguments in the letter.                                                    
               Petitioner did not provide respondent with any additional              
          documentation to consider before making the determination.                  
               On December 28, 2004, respondent sent petitioner a Notice of           
          Determination Concerning Collection Actions Under Section 6320              
          and/or 6330 with respect to the years in issue.  In the notice of           
          determination, respondent states:                                           
               A review of the administrative file indicates that                     
               statutory and administrative requirements that needed                  
               to be met with respect to the filing of the Notice of                  
               Federal Tax Lien were in fact met in this case.                        
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