Louis A. and Christine Cox - Page 5

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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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