Kelly V. Kaeckell - Page 4




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               On July 15, 2000, respondent mailed to petitioner a Final              
          Notice-–Notice of Intent to Levy and Notice of Your Right to a              
          Hearing pertaining to petitioner’s outstanding tax liabilities              
          for the years 1990 through 1996.  On August 12, 2000, petitioner            
          filed with respondent a Form 12153, Request for a Collection Due            
          Process Hearing, that included allegations challenging the                  
          proposed levy action on the ground that petitioner was not                  
          informed of the statutory provisions imposing a tax liability on            
          him.                                                                        
               On December 8, 2000, Appeals Officer Shauna Wright wrote a             
          letter to petitioner informing him of the nature of the Appeals             
          Office review process and providing him with transcripts of                 
          account for the years 1990 through 1996.  The transcripts of                
          account identified petitioner by name and Social Security number,           
          identified the type of tax and additions to tax assessed,                   
          specified the taxable years in question, and listed the amounts             
          and dates that the assessments were entered.                                
               On April 4, 2001, Appeals Officer Wright conducted an                  
          Appeals Office hearing in this matter that petitioner attended.             
          Prior to the hearing, Appeals Officer Wright reviewed TXMODA                
          transcripts of account dated October 26, 2000, regarding                    
          petitioner’s accounts for the taxable years 1990 through 1996.2             

               2  A TXMODA transcript contains current account information            
          obtained from respondent’s master file.  “TXMODA” is the command            
                                                             (continued...)           





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