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alternative has been offered, the intrusiveness of the
proposed levy is commensurate with the need to collect
the revenue efficiently and in such a manner. Mr.
Ashley was advised that the liability can be adjusted
at any time if an accurate return is filed and substan-
tiated. The sending of the Notice of Intent to Levy
should thus be sustained.
On March 29, 2000, pursuant to section 6330, the Appeals
Office issued to petitioner a notice of determination with
respect to petitioner’s taxable year 1989. That notice stated in
pertinent part:
Summary of Determination:
The Service followed its procedural, administrative and
legal guidelines in sending the Notice of Intent to
Levy.
There were no viable collection alternatives advanced
by the taxpayer.
The intrusiveness of the proposed levy is commensurate
with the need to collect the revenue efficiently.
Attached to the notice of determination was a document entitled
“Attachment - 3193". That document stated in pertinent part:
Matters Considered
Whether the Service followed its procedural, adminis-
trative and legal guidelines in issuing the Notice of
Intent to Levy.
As [sic] assessment of tax was made and notice and
demand for payment followed. Failure to pay the
amount occurred thereafter. Before levy can be
made a Notice of Intent to Levy must first be
issued. * * * The Service followed the required
procedures in issuing the Notice of Intent to
levy.
Whether any collection alternatives are advanced by the
taxpayer and the viability of such offers.
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