Sam E. Scott - Page 9




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               Petitioner sent no further communications to Appeals Officer           
          Grantham, and, accordingly, no further information was advanced             
          about any particular collection alternative.  On January 11,                
          2005, the Notice was sent to petitioner, and he timely instituted           
          this proceeding on February 9, 2005.  In essence, the Notice                
          explained that because a review of petitioner’s assets revealed             
          that he had sufficient equity to pay the tax liability in full,             
          there was no prospect for the consideration of an offer-in-                 
          compromise.  The Notice also indicated that petitioner stated               
          that he would consult with his C.P.A. and advise respondent about           
          ways to gain a tax advantage from coordination of levies, but               
          petitioner failed to provide this information.  Also reiterated             
          in the notice of determination, was that petitioner had declined            
          to discuss “the issues * * * [he] raised in * * * [his] request             
          for a hearing”.  The Notice concluded with the determination that           
          the filing of the NFTLs with the Panola County Chancery Clerk’s             
          Office in Batesville, Mississippi, for petitioner’s 1991 income             
          tax liability was sustained.                                                
               In addition to the above Notice, respondent sent the                   
          following Letters to petitioner regarding his 1991 tax liability:           
               1.  Letter CP-14:  Sent on or about November 9, 1998, which            
          normally contains payment history and contact telephone numbers.            










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