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petitioner notified of that request and respondent’s
consideration thereof or given an opportunity to participate in
any of the administrative proceedings relating thereto.
Sometime after January 19, 1999, respondent notified peti-
tioner of his right to a hearing (Appeals Office hearing) at
which he would be able to contest a proposed collection action
against him with respect to the unpaid portion of the assessed
1990 tax deficiency.
On May 24, 1999, after the North-South Carolina Appeals
Office of the Internal Revenue Service (Appeals Office) held the
Appeals Office hearing that petitioner had requested, the Appeals
Office issued to petitioner a “NOTICE OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of
determination). The notice of determination contained the
following summary of the matters that were considered at peti-
tioner’s Appeals Office hearing:
Matters Considered
The requirements of law and administrative procedures:
whether the Service met its statutory and administra-
tive requirements prior to levy.
The relevant issues: whether Mr. Miller’s claim for
“innocent spouse” relief could now be considered.
The intrusiveness of the collection action or the
proposed collection action: whether Mr. Miller’s situa-
tion warranted forbearance of the collection action
until his claim could be considered.
The matter considered by the Appeals Office relating to “Mr.
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