Charles Michael Snyder - Page 4

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          submitted a Form 12153, Request for a Collection Due Process                
          Hearing.  His case was assigned to an Appeals officer, who sent             
          petitioner a letter requesting information and scheduling an                
          administrative hearing for October 8, 2003.  Petitioner did not             
          attend the hearing.                                                         
               The Appeals officer and petitioner thereafter exchanged                
          correspondence.  Petitioner initially raised a spousal defense              
          under section 6015, but abandoned this argument because he did              
          not file joint tax returns for the years at issue.  Petitioner              
          indicated that he was unable to pay his tax liabilities but did             
          not provide financial information that the Appeals officer had              
          requested.  Petitioner also sought to challenge his underlying              
          tax liabilities, asserting that the tax reported on his 1994                
          through 1999 tax returns was incorrect.  Petitioner made various            
          contentions about losses incurred in connection with oil and gas            
          interests in Texas; however, he did not provide the Appeals                 
          officer with information concerning these interests.  The Appeals           
          officer informed petitioner that if he wished to dispute his                
          underlying tax liabilities, he should file amended returns.                 
          Petitioner did not file an amended return for any of the years at           
               Respondent issued petitioner a notice of determination on              
          October 31, 2003, sustaining the proposed levy action.  The                 
          notice of determination stated that the requirements of                     

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