Robert Ho - Page 10

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               In the proposed second amended petition lodged with the                
          Court, petitioner alleges:  (1) Respondent failed to                        
          unconditionally offer petitioner a face-to-face CDP hearing near            
          petitioner’s residence; (2) respondent denied petitioner the                
          right to audio record “any in-person interview”; (3) respondent             
          failed to verify that all applicable law or administrative                  
          procedure was met; (4) respondent’s denial to conduct the face-             
          to-face CDP hearing “prevented petitioner from offering certain             
          valid collection alternatives, such as the posting of a bond and            
          the substitution of other assets”; (5) respondent denied                    
          petitioner the right to challenge the underlying tax liability,             
          specifically, the addition to tax under section 6651(a)(3) and              
          accrued interest under section 6601;8 (6) respondent failed to              
          balance the need for efficient collection of taxes with the                 
          legitimate concern that any collection action be no more                    
          intrusive than necessary; and (7) the Appeals officer was biased.           
               By Order dated October 12, 2005, the Court calendared                  
          respondent’s motion for summary judgment, petitioner’s motion to            
          remove small tax case designation, and petitioner’s motion for              
          leave to file second amended petition for hearing at the Court’s            
          trial session in Los Angeles, California, on October 31, 2005.              

               8  See supra note 5.                                                   

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