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concluded that respondent’s determination to proceed with
collection by way of levy should be sustained.
G. Petitioner’s Petition
On January 7, 2002, petitioner filed with the Court a
Petition for Lien or Levy Action seeking review of respondent’s
notice of determination.5 The petition includes allegations
that: (1) The Appeals officer failed to obtain verification from
the Secretary that the requirements of any applicable law or
administrative procedure were met as required under section
6330(c)(1); (2) the Appeals officer failed to identify the
statutes making petitioner liable for Federal income tax; (3)
petitioner never received a “valid” notice of deficiency; i.e.,
one signed by the Secretary or someone with delegated authority
from the Secretary; (4) petitioner never received a notice and
demand for payment; and (5) petitioner was denied the opportunity
to challenge the existence or amount of his underlying tax
liability.
Petitioner attached to his petition several documents,
including copies of the cover page of the notice of deficiency
dated December 8, 1999, the Appeals officer’s May 30, 2001,
letter referencing the Pierson v. Commissioner, 115 T.C. 576
(2000) and Davis v. Commissioner, T.C. Memo. 2001-87 cases, the
5 At the time that the petition was filed, petitioner
resided in Las Vegas, Nevada.
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