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The Appeals officer sent petitioner a letter dated June 29,
2004, scheduling a hearing for July 12, 2004. The letter further
directed petitioner to file his 2002 tax return and to provide
proof of estimated tax payments for the taxable years 2002, 2003,
and 2004. On July 12, 2004, the Appeals officer received the
June 29, 2004 letter, which was returned to him marked “not
deliverable as addressed, unable to forward”.
On that same day, the Appeals officer telephoned petitioner
at which time petitioner expressed an interest in an installment
agreement. The Appeals officer directed petitioner to (1) file
petitioner’s 2002 and 2003 returns by July 28, 2004; (2) make
estimated tax payments for 2004; and (3) complete Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals. The Appeals officer then scheduled another
hearing for July 21, 2004. On July 13, 2004, the Appeals officer
sent petitioner a letter documenting the terms established in
their conversation.
On July 14, 2004, petitioner telephoned the Appeals officer
to reschedule the hearing for July 16, 2004.
D. Petitioner’s CDP Hearing
On July 16, 2004, petitioner attended a hearing with the
Appeals officer. At the hearing, petitioner again expressed an
interest in entering into an installment agreement. He requested
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