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On May 1, 2004, respondent mailed petitioner a Final Notice
of Intent to Levy and Notice of Your Right to a Hearing (notice
of levy), with respect to 1991. On May 9, 2004, petitioner
submitted Form 12153, Request for a Collection Due Process
Hearing. In his request, petitioner stated he disagreed with the
amount of the tax liability and his attorney, Randall Bailey (Mr.
Bailey), was prepared to negotiate an offer in compromise.
On May 21, 2004, respondent mailed a letter in response to
petitioner’s request for an administrative hearing, in which
respondent stated: “Thank you for your inquiry dated May 9,
2004. We are investigating and will reply by Aug. 25, 2004”. On
July 14, 2004, respondent mailed another letter to petitioner
informing him that respondent’s Appeals Office would notify him
of the date and time of his administrative hearing.
On December 21, 2004, respondent’s Appeals Office mailed
petitioner and Mr. Bailey the notice of determination sustaining
the notice of levy. In the notice of determination, Settlement
Officer Karen O’Neal found:
In our letter dated September 10, 2004, and our follow-
up letters dated October 28, 2004 and November 17,
2004, we asked you to contact us to schedule your
Collection Due Process hearing. Since you did not
contact our office, you offered no alternative to the
proposed collection action. Therefore, we made our
decision based upon the information in your case file
and computer transcripts of your account history.
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Last modified: November 10, 2007