Anthony M. Davich - Page 8

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               1998 returns.                                                          
               D.  Respondent’s Final Notice and Petitioner’s Response                
               On October 10, 2000, respondent mailed to petitioner a Final           
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing in respect of his outstanding tax liabilities for 1997              
          and 1998.                                                                   
               On or about November 4, 2000, petitioner filed with                    
          respondent Form 12153, Request for a Collection Due Process                 
          Hearing.  The request, which was accompanied by a typewritten               
          statement, included, inter alia, a challenge to the existence of            
          the underlying tax liabilities for 1997 and 1998, 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 liabilities in question.           
               E.  The Appeals Office Hearing                                         
               By letter dated May 30, 2001, Appeals Officer Richard J.               
          Sigler (the Appeals officer) acknowledged receipt of petitioner’s           
          request for an administrative hearing.  The Appeals officer then            
          went on to state, in part, as follows:                                      

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