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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
hearing.
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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Last modified: May 25, 2011