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properly might be allowed. Petitioner failed to file a brief in
accordance with the Court-ordered briefing schedule.
OPINION
This is an appeal under section 6330(d)(1) from respondent’s
determinations to proceed with proposed levies against
petitioner’s property to collect unpaid Federal income taxes,
failure to pay additions, and accrued interest for 1990 through
1994 and 1996. Section 6331(a) allows the Commissioner to
collect by levy any tax not paid within 10 days after the
Commissioner provides the taxpayer with notice and demand for
payment. With certain exceptions not relevant here, the
Commissioner is obliged to provide the taxpayer with notice
before proceeding with collection by levy on the taxpayer's
property, including notice of the administrative appeals
available to the taxpayer. Sec. 6331(d).
As part of the Internal Revenue Service Restructuring and
Reform Act of 1998 (RRA 1998), Pub. L. 105-206, sec. 3401, 112
Stat. 685, 746, Congress enacted section 6330, which generally
provides that the Commissioner may not proceed with collection by
levy on a taxpayer's property until the taxpayer has received
notice of and the opportunity for an Appeals Office hearing to
review the proposed levy. Sec. 6330(a)(1); Pierson v.
Commissioner, 115 T.C. 576 (2000); Sego v. Commissioner, 114 T.C.
604, 608 (2000). If the taxpayer is dissatisfied with the
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