Robert Ho - Page 6

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          assessment, that he would explain the reason for his disagreement           
          in a face-to-face CDP hearing, and that he would record the CDP             
               On November 3, 2004, respondent’s Appeals Office sent to               
          petitioner a letter advising petitioner that respondent assigned            
          the case to an Appeals officer.  The assigned Appeals officer               
          also sent two letters to petitioner on November 3, 2004.  In the            
          first letter, the Appeals officer acknowledged receipt of Form              
          12153 and requested petitioner to submit, within 15 days of the             
          letter, a Form 433-A, Collection Information Statement for Wage             
          Earners and Self-Employed Individuals, and petitioner’s 2003                
          return in order for the Appeals officer to consider collection              
          alternatives in a CDP hearing.  The Appeals officer also stated             
          that he would contact petitioner after 15 days from the date of             
          the letter to schedule a CDP hearing.  In the second letter, the            
          Appeals officer limited petitioner’s CDP hearing to a telephone             
          conference or discussion by correspondence because petitioner               
          raised only frivolous and groundless arguments in Form 12153.               
          The Appeals officer, however, notified petitioner that he could             
          have a face-to-face CDP hearing to address legitimate issues if             
          petitioner would so advise the Appeals officer of such issues               
          within 15 days of the date of the letter.                                   
               Petitioner responded by letter dated November 15, 2004,                
          repeating his entitlement to a face-to-face CDP hearing and his             

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