Marc Perkel - Page 4

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          submitted a Form 656, Offer In Compromise (OIC).  The Appeals               
          officer notified petitioner and his representative that                     
          additional information was required for approval of an OIC, but             
          petitioner and his representative continued to fail to provide              
          it.                                                                         
               On March 9, 2004, respondent issued to petitioner both a               
          Decision Letter Concerning Equivalent Hearing Under Section 6320            
          and/or 6330 (Decision Letter) with respect to the proposed levy,            
          and the Notice Of Determination with respect to the NFTL, both of           
          which upheld respondent’s collection actions.                               
               Petitioner filed his petition in this case as a result of              
          the Appeals Office approval of respondent’s collection actions.             
          Attached to the petition is a copy of the Decision Letter and a             
          copy of the Notice of Determination concerning 1998.  Petitioner            
          objects to respondent’s filing of the NFTL, in paragraph 4 of the           
          petition, because he has proposed an “offer and compromise” as an           
          alternative to the “levy”.                                                  
               On October 15, 2004, a Notice Setting Case For Trial was               
          issued, and this case was set for trial in January of 2005.  On             
          December 6, 2004, respondent filed a motion for continuance of              
          trial.  Respondent alleged in the motion that petitioner had                
          informed respondent on December 2, 2004, that petitioner had been           
          unaware that his OIC was incomplete.  Respondent further alleged            
          that petitioner had offered to file the necessary information for           






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