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filed petitioner’s trial memorandum as “Petitioner’s Memorandum
Brief”, and petitioner was ordered to file any supplemental
information and/or arguments by March 28, 2002. Respondent was
ordered to file a reply in the form of a brief by April 29, 2002.
On June 3, 2002, petitioner’s unsolicited response to
respondent’s reply brief was received in the form of a 1-page
letter dated May 12, 2002.
Discussion
We have jurisdiction over this matter because petitioner
filed a timely petition for review in response to respondent’s
valid notice of determination to proceed with collection. Sec.
6330(d)(1); Lunsford v. Commissioner, 117 T.C. 159 (2001);
Sarrell v. Commissioner, 117 T.C. 122 (2001); Offiler v.
Commissioner, 114 T.C. 492, 498 (2000); Goza v. Commissioner, 114
T.C. 176, 182 (2000).
Where the Commissioner intends to levy against property and
property rights of a taxpayer to collect an unpaid tax liability,
section 6331(d) requires that the taxpayer be notified of the
intent to levy. In addition, section 6330(a) requires that a
written notice be sent to the taxpayer, advising of the right to
a hearing.
Section 6330(b) affords taxpayers the right to a fair
hearing before an impartial IRS Appeals officer. Section
6330(c)(1) requires the Appeals officer to obtain verification
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