John E. Hunter, II and Alma E. Hunter - Page 7

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          There is no indication that Mr. Hunter provided the settlement              
          officer with a Form 433-A or the financial information requested            
               The settlement officer and Mr. Hunter scheduled a telephone            
          hearing for June 1, 2005.  Mr. Hunter called the settlement                 
          officer on that day, but the settlement officer had stepped out             
          of her office.  Mr. Hunter left a message, and the settlement               
          officer returned his call shortly thereafter.  The settlement               
          officer left a message with a person who identified himself as              
          Mr. Hunter’s father, asking Mr. Hunter to return her call.  It is           
          not clear whether Mr. Hunter received this message.  In any                 
          event, the settlement officer and Mr. Hunter did not speak by               
               In August 2005, respondent issued a notice of determination            
          denying Mr. Hunter relief from the notice of Federal tax lien               
          filing and the proposed levy action.  The notice of determination           
          states:  (1) Mr. Hunter failed to provide requested financial               
          information; (2) the settlement officer determined, on the basis            
          of the best information available, that the requirements of                 
          applicable law or administrative procedures had been met; and               
          (3) respondent’s proposed collection actions balance the need for           
          efficient collection of tax with the intrusiveness of the                   
          actions.  Mr. Hunter timely petitioned the Court for review of              
          the notice of determination.                                                

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