Paul L. Bowman - Page 9

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                    issued, as required by IRC Section 6322 and 6331(a),              
                    and that a levy source had been identified.                       
                    3) before any levy action was initiated, notice of                
                    intent to levy was issued in accordance with IRC                  
                    6331(d), which requires that taxpayers be notified                
                    of the intention to levy no less than thirty days                 
                    before levy action is initiated.                                  
                    4) Collection Due Process Notice was sent by cer-                 
                    tified mail, return receipt requested, to your                    
                    last known address.                                               
                    5) The Automated Collection Site attempted to                     
                    resolve your case, but was unable to do so.                       
                    Therefore, your file was forwarded for appeals                    
                    consideration promptly upon receipt of your hear-                 
                    ing request.                                                      
                    6) internal account transaction codes were entered                
                    timely to place your accounts in suspended status                 
                    pending the outcome of the due process hearing                    
                    7) the Settlement Officer in this case has had no                 
                    prior involvement with you concerning the taxes at                
                    issue in this due process proceeding, pursuant to                 
                    requirements of IRC 6330.                                         
                               ISSUES RAISED BY THE TAXPAYER                         
                    1) no specific issues concerning liability or                     
                    collection procedures were raised.                                
                    Rather, you indicated only that you wished                        
                    a face-to-face hearing, which you intended                        
                    to tape record, and that details would be                         
                    disclosed at the hearing.  You referenced                         
                    only the tax reform act of 1998 as the                            
                    reason for your hearing request.                                  
                    Finding:  Appeals is not obligated to address the                 
                    types of nonspecific issues contained in your                     
                    request, as you were advised in our conference                    
                    letter.  You did not submit specific, legitimate                  
                    issues for discussion in writing to qualify for a                 
                    face-to-face conference.  You were offered an                     
                    opportunity for a telephone conference, but failed                
                    to contact the Settlement Officer.                                

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