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and the issuance of the final notice of intent to levy on
September 5, 2001. See supra C and D.
Petitioner filed an Objection to respondent’s motion.
Thereafter, pursuant to notice, respondent’s motion was called
for hearing at the Court's motions session in Washington, D.C.
Although petitioner did not attend the hearing, he submitted two
“Motions Session Documents”, the first of which was filed as a
Supplement to his Objection9 and the second of which was filed as
his Rule 50(c) Statement.
Discussion
Section 6331(a) provides that if any person liable to pay
any tax neglects or refuses to pay such tax within 10 days after
notice and demand for payment, the Secretary is authorized to
collect such tax by levy on the person’s property. Section
6331(d) provides that at least 30 days before enforcing
collection by levy on the person's property, the Secretary is
obliged to provide the person with a final notice of intent to
levy, including notice of the administrative appeals available to
the person.
9 Petitioner’s Supplement is virtually identical to his
Objection.
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