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liabilities for 1995, 1997, and 1998. In the notice, the Appeals
Office concluded that respondent’s determination to proceed with
collection by way of levy should be sustained.
G. Petitioner’s Petition and Amended Petition
On March 25, 2002, petitioner filed with the Court a
Petition for Lien or Levy Action seeking review of respondent’s
notice of determination.9 Thereafter, on June 19, 2002, an
Amended Petition for Lien or Levy Action was filed.
In the amended petition, petitioner challenges “the
appropriateness of (the) collection action” and “the existence of
the underlying liability”. Petitioner also alleges: (1) The
Appeals officer failed to obtain verification from the Secretary
that the requirements of applicable law or administrative
procedure were met as required under section 6330(c)(1); (2)
petitioner never received notice and demand for payment for the
liabilities in issue; and (3) no “valid” assessment was ever
made. Finally, petitioner alleges that he never received a
“valid notice of deficiency” for any of the years in issue. The
amended petition contains no facts in support of any of the
foregoing allegations.
H. Respondent’s Motion For Summary Judgment
As stated, respondent filed a Motion For Summary Judgment
9 At the time that the petition was filed, petitioner
resided in Pahrump, Nevada.
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