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28, 2003, respondent reversed the abatements and reinstated the
1996 and 1998 assessments. Respondent subsequently sent
petitioner notices of balance due for the unpaid balances of the
1996, 1997, 1998, and 2000 assessments.
On October 25, 2003, respondent mailed to petitioner a Final
Notice of Intent to Levy and Your Right to a Hearing Under
Section 6330. In response, petitioner submitted a timely request
for a section 6330 hearing, attaching to it a nine-page statement
containing mostly frivolous and groundless arguments.
Petitioner’s case was originally assigned to Settlement
Officer S. Gropack (Officer Gropack). After reviewing
petitioner’s request for a hearing, Officer Gropack mailed to
petitioner a letter dated January 21, 2005, indicating that (1)
the Appeals Office does not provide a face-to-face hearing if the
only issues raised are frivolous or groundless, (2) the arguments
included in petitioner’s hearing request are frivolous or
groundless, (3) petitioner is not entitled to a face-to-face
hearing if the only issues raised are frivolous and groundless,
and (4) petitioner could have a telephone or correspondence
hearing to discuss any relevant challenges to respondent’s
proposed collection action. Officer Gropack scheduled a
telephone hearing for February 24, 2005, but also informed
petitioner that if he wanted to have a face-to-face
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Last modified: November 10, 2007