Said Jumaa - Page 3

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               On November 23, 2005, respondent issued to petitioner a                
          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to his taxable year 1998.           
               On December 20, 2005, in response to the notice of intent to           
          levy, petitioner mailed to respondent Form 12153, Request for a             
          Collection Due Process Hearing (petitioner’s Form 12153), and               
          requested a hearing with respondent’s Appeals Office (Appeals               
          Office).  Petitioner’s Form 12153 stated:  “The amount of tax is            
          totally exaggerated.  I’ll explain other reason later.”                     
               On April 24, 2006, a settlement officer with the Appeals               
          Office (settlement officer) sent a letter to petitioner (April              
          24, 2006 letter) with respect to petitioner’s Form 12153.  That             
          letter stated in pertinent part:                                            
               I have scheduled a telephone conference call for you on                
               June 13, 2006 at 10:00a.m.  This call will be your CDP                 
               Please call me at * * * at the date and time indicated                 
               If this time is not convenient for you, or you would                   
               prefer your CDP hearing to be held by face-to face                     
               conference at the Appeals office closest to your cur-                  
               rent residence or, if you are a business, the Appeals                  
               office closest to your business address, or by corre-                  
               spondence, please let me know within fourteen (14) days                
               from the date of this letter.                                          
                  *       *       *       *       *       *       *                   
               Regarding the liability you are raising:                               
               The return was prepared by the Service when you failed                 
               to file your return as required.  A Statutory Notice of                
               Deficiency would have been issued, which would have                    

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Last modified: November 10, 2007