Hugh D. Summers and Teresa E. Summers - Page 11

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          face-to-face hearing and acknowledging that alternative                     
          collection methods needed to be explored at this meeting, and               
          stating that he was not available for the telephone conference on           
          April 28.                                                                   
               On April 28, 2005, Ms. Dermody sent petitioners a letter to            
          which she attached a copy of the Form 12153, and in which she               
          advised petitioners that if they wanted a face-to-face hearing              
          they must contact her within 15 days and describe the legitimate            
          issues they wished to raise.  Ms. Dermody also advised                      
          petitioners that they must complete a Form 433-A, Collection                
          Information Statement for Wage Earners and Self Employed                    
          Individuals, and return it along with their 2003 and 2004 tax               
          returns by May 13, 2005.                                                    
               On May 13, 2005, Mr. Summers sent Ms. Dermody a letter in              
          which he raised the following issues:  (1) That Ms. Dermody was a           
          settlement officer, not an independent Appeals officer, and that            
          it was improper for her to hold the hearing; (2) that respondent            
          violated the “CDP statutes” by not holding a section 6330 hearing           
          for more than 3 years from the date of the request; and (3) that            
          petitioners did not have any tax liability for 1989 because the             
          IRS improperly credited the payments from Commonwealth, and that,           


               5(...continued)                                                        
          his former attorney, Jerry Arthur Jewett, who had since been                
          disbarred, may have made the request without sending petitioners            
          a copy.                                                                     





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