John Haynes, Jr. - Page 5




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          Goldammer), on October 25, 2004.  In the letter, Mr. Callanan               
          scheduled a CDP hearing by telephone on November 15, 2004, and              
          also offered Mr. Goldammer an opportunity to have either a face-            
          to-face conference or a hearing by correspondence.  The November            
          15, 2004, hearing was continued until December 16, 2004.                    
               Petitioner requested a face-to-face conference, which was              
          held on December 16, 2004, with petitioner, Mr. Callanan, and Mr.           
          Goldammer in attendance.  A second face-to-face conference                  
          occurred between Mr. Callanan and Mr. Goldammer on February 4,              
          2005.                                                                       
               At the December 16, 2004, conference, petitioner                       
          acknowledged that he had received the notice of deficiency but              
          had relied on his representative at that time to file a petition            
          with the Court.  Petitioner acknowledged that it was his                    
          responsibility to assure that a petition was filed with this                
          Court and that he had failed in this duty.  After this admission,           
          Mr. Callanan explained to petitioner that because he had received           
          a notice of deficiency, the merits of the underlying deficiencies           
          could not be raised as part of the CDP hearing.  The parties then           
          discussed the appropriateness of the collection action, the                 
          filing of the Notice of Federal Tax Lien, and possible collection           
          alternatives.                                                               
               With respect to the collection alternatives discussed at the           
          December 16, 2004, CDP hearing, petitioner requested that any               







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