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face section 6330 hearing on the issues he raised in his hearing
request because they have been determined by the courts to be
frivolous or issues that the Appeals Office does not consider.
Ms. Clinger offered petitioner a telephone conference on November
18, 2004. Ms. Clinger also advised petitioner that he had 15
days to submit a list of relevant and nonfrivolous matters (such
as submitting collection alternatives) that he wished to discuss
at the section 6330 hearing, in which case he would be granted a
face-to-face section 6330 hearing.
On November 3, 2004, petitioner sent a letter to Ms. Clinger
containing frivolous and groundless arguments and stated that he
wanted a face-to-face section 6330 hearing.
On November 18, 2004, Ms. Clinger called petitioner but did
not speak to him. She left a message on an answering machine
with her name and telephone number. Petitioner did not call Ms.
Clinger back.
Ms. Clinger reviewed the administrative file for 2001 and
confirmed that respondent had complied with all applicable laws
and administrative procedures regarding 2001. During this
review, Ms. Clinger discovered that petitioner’s assessment for
2001 was too high, and, even though petitioner was not entitled
to challenge his underlying liability in the section 6330
hearing, she had the assessment corrected (i.e., it was partially
abated).
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Last modified: November 10, 2007