Edward W. Clough - Page 3

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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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