Said Jumaa - Page 5

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          hearing, petitioner claimed that his liability for his taxable              
          year 1998 was incorrect because, according to petitioner, he made           
          some money in the stock market and later lost everything.                   
          Petitioner provided no documents or specific information to                 
          establish his claim during the hearing that his liability for his           
          taxable year 1998 was incorrect.  During the hearing, petitioner            
          indicated that he did not recall whether he received a notice of            
          deficiency relating to his taxable year 1998.  Petitioner further           
          stated that he was unable to pay petitioner’s unpaid liability              
          for 1998.  Petitioner acknowledged during the hearing that he had           
          not filed tax returns and indicated that he might need profes-              
          sional help.  During the hearing, the settlement officer reminded           
          petitioner that no collection alternatives were available because           
          he had not filed his delinquent tax returns and did not submit              
          the financial information that the settlement officer requested             
          in the April 24, 2006 letter.  The settlement officer advised               
          petitioner during the hearing that she intended to issue a notice           
          of determination with respect to petitioner’s unpaid liability              
          for 1998.                                                                   
               On June 28, 2006, the Appeals Office issued to petitioner a            
          notice of determination concerning collection action(s) under               
          section 6320 and/or 6330 (notice of determination).  That notice            
          stated in pertinent part:                                                   

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