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other to 2000. With each he enclosed an attachment explaining
petitioners’ disagreement with the proposed levy. Cover
materials from Mr. Merriam communicated an understanding that the
Form 12153 for 1999 would be treated as a request for an
“equivalent” hearing. With respect to both years, petitioners
sought less intrusive methods of collection, “including but not
limited to * * * an installment agreement or an offer in
compromise”, and requested abatement of delinquency additions to
tax.
By a letter dated May 23, 2003, Bruce H. Skidmore
(Mr. Skidmore), the Appeals officer to whom petitioners’ case had
been assigned, scheduled a hearing for June 18, 2003, and
provided general information concerning the requisites for an
installment agreement or offer-in-compromise. The letter noted
that consideration of collection alternatives required taxpayers
to be in current compliance with filing and payment obligations
and to submit current financial information; i.e., Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals, and/or Form 433-B, Collection Information
Statement for Businesses. The hearing was twice rescheduled at
petitioners’ request, on grounds of needing more time to prepare
and submit returns for 2001 and 2002 and Forms 433-A and B. A
telephone conference was eventually set for August 12, 2003.
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