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hearing, he would have to send a letter to Officer Gropack
describing the legitimate issues he wished to discuss.
On February 24, 2005, petitioner submitted a letter to
Officer Gropack containing frivolous and groundless arguments and
a request for a face-to-face hearing at the closest Appeals
Office to petitioner’s residence. Respondent transferred
petitioner’s case to the Boston Appeals Office, where it was
assigned to Settlement Officer Lisa Boudreau (Officer Boudreau or
hearing officer). By letter dated June 14, 2005, Officer
Boudreau advised petitioner that he did not qualify for a face-
to-face hearing because the arguments he had presented were
frivolous. Officer Boudreau reiterated that petitioner would
only receive a face-to-face hearing if he presented legitimate
issues. In the alternative, Officer Boudreau offered petitioner
a telephone hearing and the right to discuss by correspondence
any relevant challenges to the proposed levy. In a letter dated
July 9, 2005, petitioner continued to assert frivolous arguments,
refused to participate in a telephone hearing, and reiterated his
request for a face-to-face hearing.
On October 19, 2005, the Appeals Office issued to petitioner
a Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination) with respect
to petitioner’s outstanding tax liabilities for the years in
issue. In the notice of determination and an attachment to the
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Last modified: November 10, 2007