Michael J & Janice L Patriot
Monroe, NC 28112-7765

Date: August 27, 2007>

Cheryl Wakefield
Internal Revenue Service
Memphis Appeals Campus
PO Box 622, Stop 86
Memphis, TN 38101-0622

Dear Ms Wakefield,

This letter is to acknowledge that we received your letter dated August 15, 2007 stating that you wanted to hold a telephone conference call (CDP) on September 5, 2007 at 10:00 am EDT. You also stated in your letter that this was going to be our CDP hearing and that we would not be afforded a face-to face hearing as we had requested.

It is our understanding that Section 6330 provides that a person is entitled to an administrative hearing before an impartial Appeals Officer before the IRS can proceed to collect unpaid taxes by way of a levy. Under Section 6330(c)(2)(A) a person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including? (i) appropriate spousal defenses; (ii) challenges to the appropriateness of collection actions; and (iii) offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-compromise. Also under Section 6330(c)(2)(B) a person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability. In addition, under Section 6330(c)(1) the appeals officer shall at the hearing obtain verification from the Secretary that the requirements of any applicable law or administrative procedure have been met.

Therefore, since we feel that we have met the requirements of us, we feel the we should be afforded a face-to-face meeting in Charlotte, NC. We also plan on recording the proceedings and will have a witness coming with us.


Michael J Patriot
Janice L Patriot