Dominic Calafati - Page 3

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          petitioner was entitled to be informed, before the beginning of             
          his section 6330 telephone hearing, of respondent’s post-Keene              
          policy that a face-to-face section 6330 hearing is the only                 
          section 6330 hearing section 7521(a)(1) entitles a taxpayer to              
          audio record.  Petitioner was a resident of Lansdale,                       
          Pennsylvania, when his petition in this case was filed.                     
               Petitioner timely filed his 1998 individual Federal income             
          tax return.  On April 3, 2002, respondent issued a notice of                
          deficiency (notice) in which he determined that petitioner was              
          liable for an income tax deficiency of $8,173 and an accuracy-              
          related penalty, pursuant to section 6662(a), of $1,634.60 for              
          1998.  Petitioner sent a letter dated May 14, 2002, to the                  
          Internal Revenue Service (the Service) appealing the notice, but            
          he did not petition this Court to review the notice.  On August             
          26, 2002, respondent assessed the deficiency for 1998.                      
               On December 21, 2002, respondent issued a Final Notice of              
          Intent To Levy and Notice of Your Right to a Hearing with regard            
          to petitioner’s unpaid tax liability for 1998.  On or around                
          December 30, 2002, petitioner timely submitted a Form 12153,                
          Request for a Collection Due Process Hearing (section 6330                  
          hearing), in which he contended that “The administrative record             
          contains egregious errors, and the correction of those errors               
          will mitigate collection activity.  Additionally, several                   
          procedural errors were committed violating administrative due               

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