James D. Horn - Page 16

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          properly might be allowed.  Petitioner failed to file a brief in            
          accordance with the Court-ordered briefing schedule.                        
               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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