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have a court reporter and cross-examine witnesses at the
hearing.2 The only issues petitioner raised at the hearing were
the validity of the assessment for 1995 and 1996 and an issue
regarding a levy.3 The issue regarding the levy was resolved at
the hearing as no levy had taken place.
During the hearing, Mr. Roberts acknowledged that petitioner
had received the RACS report and petitioner’s transcripts of
account for 1995 and 1996. Ms. Villa reviewed the transcripts of
account provided to petitioner by Mr. Morrison and then-current
transcripts of account for 1995 and 1996 to verify the name of
petitioner, the tax periods, the type of tax, the date of the
assessments, and the amount of the assessments. In verifying the
accuracy of the assessments, Ms. Villa compared the amounts
determined in the notices of deficiency for 1995 and 1996 with
the amounts assessed on petitioner’s transcripts of account.
These numbers matched.
On August 29, 2000, respondent mailed petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330, for 1995 and 1996 determining to proceed with
collection.
2 Respondent, however, allowed Mr. Roberts to tape record
the hearing.
3 During the hearing, petitioner did not raise the
underlying tax liabilities, any collection alternatives, or the
appropriateness of the proposed collection activities, nor did he
identify any irregularities in the assessment process.
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