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aforementioned Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330, sustaining the proposed
levy action. Petitioner’s petition challenging this notice was
filed on February 24, 2004, and reflected an address in
Hazlehurst, Mississippi. She therein expressed her request for
relief as follows: “I am requesting to extend the period of
payment, due to the fact that I am currently on disability and
have medical payments, [illegible] medical insurance payment due.
I don’t know when I’ll be returning to work, but I do need an
extension on the payment period.”
On October 5, 2004, John F. Driscoll, trial counsel for
respondent in this case, sent to petitioner a letter explaining
his intent to file a motion for summary judgment and inviting
petitioner instead to contact him within 10 days if she wished to
discuss any offer of payment to resolve the case or to provide
any additional relevant financial information. Thereafter, on
October 18, 2004, Mr. Driscoll reached petitioner by telephone,
and during that conversation petitioner displayed some interest
in providing additional information in an attempt to reach a
settlement of her case. The parties agreed that Mr. Driscoll
would provide petitioner with a new Form 433-A and that
petitioner in the near future would submit any additional
information or offer of settlement that she wished to be
considered in connection with this case. Mr. Driscoll then sent
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