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through 1988.2 Respondent concedes that the notice required by
section 6320(a) was not mailed to petitioner at his last known
address and that such notice was therefore invalid. See sec.
6320(a)(2)(C). In any event, petitioner did not request an
administrative hearing with the Internal Revenue Service Office
of Appeals (Appeals Office) in respect of the notice required by
section 6320(a), nor did the Appeals Office either conduct an
administrative hearing or issue a determination letter regarding
the notice required by section 6320(a).
On or about October 25, 1999, respondent mailed to
petitioner a Final Notice Of Intent To Levy And Notice Of Your
Right To A Hearing (notice of intent to levy) concerning
petitioner’s unpaid tax liabilities for the years 1984 through
1988.3 The notice of intent to levy was mailed to petitioner at
his last known address. See sec. 6330(a)(2)(C). Petitioner
actually received the notice of intent to levy on October 27,
1999, as reflected by the U.S. Postal Service Form 3811, Domestic
Return Receipt, that was signed at the time that the notice was
2 The notice required by sec. 6320(a) listed petitioner’s
tax liabilities as $19,372.79, $715.29, $15,010, $1,618.23, and
$2,189.94 for the years 1984, 1985, 1986, 1987, and 1988,
respectively.
3 The notice of intent to levy stated that petitioner owed
amounts from prior notices, additional penalties, and interest
totaling $24,198.16, $886.24, $18,939.59, $2,053.57, and
$2,797.52 for the years 1984, 1985, 1986, 1987, and 1988,
respectively.
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