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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
hearing.
Please call me at * * * at the date and time indicated
above.
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