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Process Hearing (Form 12153). Petitioner attached the following
statement to Form 12153:
I. NOTICE OF INTENT TO LEVY - Explanation for Disagree-
ment
Income. (1) There was a failure to issue
Notices of Deficiency; (2) There was a failure to
generate an assessment list; (3) There was a failure of
the Commissioner to certify and transmit the assessment
list; (4) There was a failure to record the assessment;
(5) There was a failure to provide record of assess-
ment; and, (6) There was a failure to send Notice of
Assessment.
On May 17, 2001, the Internal Revenue Service (IRS) Appeals
officer (Appeals officer) assigned to petitioner’s case sent
petitioner a letter (May 17, 2001 letter) in response to peti-
tioner’s Form 12153. That letter stated in pertinent part:
I have received your Request for a Collection Due
Process Hearing dated September 7, 2000, and I have
reviewed the information in the administrative file.
The assessments for both the 1992 and 1995 returns are
based upon returns that were either signed by you and
Mr. Armstrong (1992) or by an authorized representative
because you were out of the country (1995). No liabil-
ity questions exist for these two years. If you be-
lieve either assessment is incorrect you should file an
amended Form 1040X for these years correcting the tax
liability.
As part of IRC � 6330 two items that need to be ad-
dressed as part of a collection due process hearing are
alternative and least intrusive means of collection.
In order to facilitate the resolution of your Request
for a Collection Due Process Hearing, provide the
following information no later than June 1, 2001.
1. A completed Form 433A, Collection Information
Statement for Individuals.
2. A completed Form 433B, Collection Information
Statement for Businesses (if self employed)[.]
3. Copies of your last six months bank statements.
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