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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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