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A hearing was subsequently set for February 9, 2006, by
Settlement Officer Danny L. Williams (Williams). In a letter
dated January 24, 2006, petitioner requested a delay, and a
hearing was set for March 15, 2006. Prior to and during the
hearing, petitioner demanded certain information concerning the
grant of relief under section 6015(f) to his former spouse.
Williams sent to petitioner instructions for submitting a Freedom
of Information Act request. A hearing was conducted on March 15,
2006, and additional documents were sent by petitioner to
Williams after the hearing. There was no tape-recording or
transcript of the section 6330 hearing conducted by Williams with
petitioner on March 15, 2006, nor was one requested by petitioner
prior to the section 6330 hearing date. On April 13, 2006, the
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330, signed by an Appeals Team Manager, was
sent to petitioner.
The notice of determination set forth petitioner’s various
claims and accepted only petitioner’s contention with respect to
2003 and 2004. The notice analyzed petitioner’s financial
information and concluded that an offer-in-compromise was not a
viable collection alternative because he had more than sufficient
equity in his assets to pay his liability in full. The notice
stated that petitioner had been given notice of and an
opportunity to participate in the action on his former spouse’s
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Last modified: November 10, 2007