Fred A. Windover - Page 7




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         dated June 2, 2004, respondent notified petitioner that he had               
         received petitioner’s abatement request and requested further                
         information, regarding petitioner’s personal and financial                   
         difficulties. Petitioner did not respond to respondent’s letter              
         or submit any additional information.                                        
              By letter dated June 26, 2004, respondent notified                      
         petitioner of his intent to levy with respect to petitioner’s                
         then outstanding 1999 tax liability.  That letter also advised               
         petitioner of his right to request an administrative hearing                 
         with regard to respondent’s proposed levy.  According to the                 
         letter, petitioner’s outstanding 1999 tax liability, including               
         interest and additions to tax, totaled $18,097.61.  Petitioner,              
         on July 20, 2004, made a timely request for an administrative                
         hearing.  See sec. 6330(a) and (b).                                          
              Before an administrative hearing was conducted (or even                 
         scheduled), respondent caused a Notice of Federal Tax Lien (NFTL)            
         to be filed on August 12, 2004, and duly notified petitioner of              
         the event by certified mail on August 19, 2004.  Like the                    
         proposed levy, the NFTL related to petitioner’s then outstanding             
         1999 tax liability.  In response to respondent’s August 19, 2004,            
         letter notifying him about the NFTL, petitioner timely requested             
         an administrative hearing.  See id.                                          










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