Leonard O. Parker, Jr. - Page 8

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          Form 433-A.2  The letter further stated that if Mr. Climan did              
          not “receive such documents by January 5, 2005, [he would] make a           
          determination based on the information contained in the case                
          file.”  In addition to the letter, petitioner was provided all              
          the necessary forms with accompanying instructions on how to                
          complete an offer-in-compromise.                                            
               Petitioner failed to submit the offer or any financial                 
          statement.  As a result, no collection alternatives were                    
          considered.  Mr. Climan closed the case and determined the NFTL             
          was appropriate and in accordance with all procedural guidelines.           
              A further trial of this case was held in Los Angeles,                   
         California, on March 23, 2005.  At trial, petitioner reiterated              
         the issues presented during the section 6320 hearing.  Petitioner            
         further asserted that the Appeals officer at that hearing had not            
         addressed the issues and concerns raised, but had attempted to               
         talk him into submitting another offer-in-compromise.  Petitioner            
         testified he did not submit the offer-in-compromise because he               
         could not afford the $150 application fee.  In addition, he                  
         disagreed with Mr. Climan over whether the recorded lien would               
         remain in effect until the compromised balance of the tax                    
         liability was completely paid.                                               

               2 Form 433-A, Collection Information Statement for Wage                
          Earners and Self Employed Individuals.                                      

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