Charles Michael Snyder - Page 3

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               This proceeding arises from a petition for judicial review             
          filed in response to a Notice of Determination Concerning                   
          Collection Action(s) Under Section 6320 and/or 6330 (notice of              
          determination) sent to petitioner on October 31, 2003.  The issue           
          for decision is whether respondent abused his discretion in                 
          determining that the proposed levy action to collect petitioner’s           
          unpaid Federal income tax for 1994 through 1999 should proceed.             
               The facts have been stipulated, and they are so found.  This           
          case was submitted fully stipulated pursuant to Rule 122.  At the           
          time his petition was filed, petitioner resided in Portland,                
               Petitioner filed Federal income tax returns for the taxable            
          years 1994 through 1999 but did not pay in full the tax he                  
          reported.  Respondent assessed the taxes shown on petitioner’s              
          returns, but eventually designated his account “currently not               
          collectible”, meaning that respondent would suspend enforced                
          collection of petitioner’s outstanding tax liabilities.  After              
          petitioner failed to file his 2001 tax return, however,                     
          respondent removed the “currently not collectible” designation              
          and proceeded with collection efforts.                                      
               In March 2003, respondent sent petitioner a Final Notice Of            
          Intent To Levy And Notice Of Your Right To A Hearing with respect           
          to the taxable years 1994 through 1999.  Petitioner timely                  

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