Frank Lopez - Page 4




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          and for 1996, in which respondent informed petitioner that, in              
          order to contest the proposed lien filings, petitioner must                 
          request a CDP hearing within 30 days.                                       
               On September 30, 1999, respondent received from petitioner a           
          Form 12153, Request for a Collection Due Process Hearing, in                
          which petitioner requested a CDP hearing with respect to the                
          above proposed levy and the proposed lien filings.                          
               Sometime after September 30, 1999, respondent denied                   
          petitioner a CDP hearing with respect to the proposed levy, but             
          respondent granted petitioner a CDP hearing with respect to the             
          proposed lien filings.                                                      
               Respondent, however, did grant petitioner an equivalent                
          hearing under section 301.6330-1T(i), Temporary Proced. & Admin.            
          Regs., 64 Fed. Reg. 3413 (Jan. 22, 1999), with respect to the               
          proposed levy.                                                              
               On August 30, 2000, at the conclusion of the equivalent                
          hearing, respondent issued to petitioner a decision letter in               
          which respondent concluded that respondent’s Levy Letter was                
          properly mailed to petitioner at petitioner’s last known address,           
          that petitioner’s request for a CDP hearing with regard to the              
          proposed levy was untimely, and that petitioner was not entitled            
          to any relief with regard to the proposed levy.                             
               On September 7, 2000, with respect to the proposed lien                
          filings, respondent issued to petitioner a notice of                        






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