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provided petitioner with a copy. Appeals did not grant
petitioner’s request to subpoena witnesses and documents for
purposes of the Appeals hearing. Subsequently, Appeals sent a
“notice of determination” to petitioner. This notice contained
the following pertinent language:
NOTICE OF DETERMINATION
CONCERNING COLLECTION ACTIONS UNDER SECTION 6330
Dear Mr. Davis:
We have reviewed the proposed collection action for the
period shown above. This letter is your legal Notice
of Determination, as required by law. A summary of our
determination is stated below and the enclosed
statement shows, in detail, the matters we considered
at your Appeals hearing and our conclusions.
* * * * * * *
Summary of Determination:
The Service’s position that the assessment is valid is
supported. No evidence was presented that Mr. Davis is
a nonresident alien nor that he had no trade or
business or income from sources in the US. Mr. Davis
did not provide valid income tax returns, evidence that
he was not liable for taxes nor did he address any
method of paying the tax liability. A copy of the
Certificate of Records Payment Form 4340 was provided
to Mr. Davis.
The enclosed statement stated:
ATTACHMENT - 3193
With the best information available, the requirements
of various applicable law and administrative procedures
have been met. The assessments are based on
substitutes for returns. The only legal requirements
before taking general enforcement action are the notice
and demand and the notice of intent to levy and notice
of right to a collection due process hearing. Computer
records indicate that the appropriate notices were sent
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Last modified: May 25, 2011