Edward W. Clough - Page 4

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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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