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property within the Coeur d’Alene Indian reservation when his
petition was filed.
Pursuant to section 6331, respondent notified petitioner on
September 14, 1999, that respondent intended to levy upon
petitioner’s property in order to collect Federal income taxes
and additions thereto and/or penalties (collectively, taxes)
claimed due from petitioner for 1986 through 1996. The liens
against the property subject to the proposed levy for the 1986
through 1991 taxes were filed in Kootenai and Benewah Counties,
Idaho, on February 20, 1997. The liens against the property
subject to the proposed levy for the 1992 through 1995 taxes were
filed in Kootenai County, Idaho, on September 15, 1997, and in
Benewah County, Idaho, on September 12, 1997. The lien against
the property subject to the proposed levy for the 1996 taxes was
filed in Benewah County, Idaho, on December 12, 1998.
Petitioner requested a hearing under section 6330 to review
respondent’s proposed levy. Respondent’s Office of Appeals
reviewed the proposed levy and determined in a notice of
determination that “Appeals should not restrict the appropriate
collection action.” The notice of determination states:
. The Secretary has provided sufficient
verification that the requirements of any
applicable law or administrative procedure
has [sic] been met.
. Your Request for a Collection Due Process
Hearing was submitted under IRC �6330,
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Last modified: May 25, 2011