Peter D. Dahlin Attorney at Law, P.S. - Page 3




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          and complained about “the failure to send 4340 forms with 23C               
          dates”.2                                                                    
               On March 11, 2005, the Appeals officer assigned to                     
          petitioner’s case, Kathleen Derrick (Ms. Derrick), mailed to                
          petitioner a letter entitled We Received Your Request for A                 
          Collection Due Process Hearing And We Need To Advise You On                 
          Procedures.  The letter informed petitioner that the issues                 
          petitioner raised in its Appeals hearing request on Form 12153              
          were frivolous or groundless.  The letter provided:                         
               Appeals does not provide a face-to-face conference if                  
               the only items you wish to discuss are those mentioned                 
               above.  You may, however, have a telephone conference                  
               or discuss with us by correspondence any relevant                      
               challenges to the filing of the notice of federal tax                  
               lien or the proposed levy.                                             
               *    *    *    *    *                                                  
               If you are interested in receiving a face-to-face                      
               conference, you must be prepared to discuss issues                     
               relevant to paying your tax liability.  These include,                 
               for example, offering other ways to pay the taxes you                  
               owe, such as an installment agreement or offer in                      
               compromise.  The Internal Revenue Manuel determines                    
               whether Appeals can accept your proposal.  If you wish                 
               to have a face-to-face conference, please write me                     
               within 15 days from the date of this letter and                        
               describe the legitimate issues you will discuss.                       
          The letter further provided that petitioner was scheduled for a             
          telephonic hearing on March 30, 2005, at 10 a.m.  Additionally,             
          the letter instructed petitioner to fill out Form 433-B,                    

               2A “23C date” is the date on which the actual assessment of            
          the tax liability was made.                                                 






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