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C. Respondent’s Final Notice and Petitioner’s Response
On August 10, 2000, respondent mailed to petitioner and his
wife a Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing in respect of their outstanding tax liability
for 1997.
On August 24, 2000, petitioner and his wife filed with
respondent Form 12153, Request for a Collection Due Process
Hearing. The request included, inter alia, a challenge to the
existence of the underlying tax liability for 1997, as well as
allegations that petitioner was never provided with a valid
notice of deficiency or notice and demand for payment and that
the Appeals officer had failed “to identify the statute that
makes me ‘liable to pay’ the taxes at issue”. Petitioner also
requested verification from the Secretary that all applicable
laws and administrative procedures were followed with regard to
the assessment and collection of the tax liability in question.
D. The Appeals Office Hearing
On April 11, 2001, petitioner attended an administrative
hearing in Las Vegas, Nevada conducted by Appeals Officer Lavada
Harmon (the Appeals officer). At the hearing, the Appeals
officer provided petitioner with a literal “plain English”
transcript of petitioner’s account for the taxable year 1997.
During the hearing, petitioner requested that the Appeals
officer identify the statutory provisions establishing
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