- 3 - 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 havePage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007