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On July 14, 2005, a representative of respondent (respon-
dent’s representative) spoke on the telephone with petitioner
Mark Freme (Mr. Freme) regarding petitioners’ Form 12153. During
that telephone call, Mr. Freme indicated that he wanted an
installment agreement. On July 14, 2005, respondent’s represen-
tative faxed, inter alia, Form 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals (Form
433-A), to petitioners. Respondent’s representative did not
receive from petitioners completed Form 433-A. On July 29, 2005,
respondent’s representative forwarded to the Appeals Office
petitioners’ Form 12153.
On September 13, 2005, an Appeals officer with the Appeals
Office (Appeals officer) sent petitioners a letter. That letter
stated in pertinent part:
This letter is in response to your Request for a Col-
lection Due Process Hearing. The Appeals’ office is
hereby offering you a hearing by phone, letter, or in-
person. It is important you contact me by September
28, 2005 to discuss your hearing.
* * * * * * *
If you wish to propose collection alternatives such as
an installment agreement or an offer in compromise, you
must submit current financial information. I have
enclosed a Collection Information Statement for Wage
Earners and Self-Employed Individuals; Form 433-A, for
this purpose. Please forward the completed Form 433-A
to me by September 28, 2005.
* * * * * * *
Please note if I don’t hear from you to discuss your
case, your hearing may consist of a review by Appeals
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Last modified: November 10, 2007