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Under Section 6320 and/or 6330”. In pertinent part, the document
states:
We have determined that the Notice of Intent to Levy
issued on the period listed above [1999] is valid and
appropriate. All legal and procedural requirements
were met in its issuance. The information you provided
concerning the check the Service shows was returned for
insufficient funds was not adequate to prove that a
valid payment was ever received. You raised no other
issues, and did not request a collection alternative.
By the answer, respondent denies petitioner’s assignment of
error.
The facts stipulated by the parties are set forth in four
numbered paragraphs in the stipulation of facts. The first
paragraph states petitioner’s address in London, England, at the
time the petition was filed. The second paragraph states his
Social Security number. The third paragraph states the date on
which the determination was issued, that it relates to
petitioner’s 1999 taxable year, and that a copy of it is
attached. The fourth paragraph states that a literal transcript
of account (the transcript of account) for petitioner’s 1999
taxable year is attached. The copy of the determination attached
to the stipulation of facts is identical to the document attached
to the petition. The transcript of account is dated April 13,
2007. It shows an account balance of $360,929.37 and has
sequential entries showing a payment in the amount of $106,888
and a dishonored check in the same amount. The parties have
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Last modified: March 27, 2008