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officer provided petitioner with a copy of that document.
During the hearing, petitioner requested that the Appeals
officer provide verification from the Secretary of the Treasury
that all applicable laws and administrative procedures had been
followed in the assessment and collection process. Petitioner
was informed that Form 4340 was sufficient to satisfy the
verification requirement of section 6330(c)(1). Petitioner also
alleged that he never received “the statutory notice and demand
for payment” and challenged the Appeals officer to
show me the law that requires me to pay the tax. You
show me the law that makes me liable for the tax in the
Internal Revenue Code [placing Internal Revenue Code in
front of Appeals officer] it’s right here in front of
you, on the table. You point to the Code, and I
brought my checkbook with me, I will write you a check
today.
The Appeals officer terminated the hearing after petitioner
declined to discuss collection alternatives.
E. Respondent’s Notice of Determination
On October 16, 2001, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 with regard to his tax
liability for 1998. In the notice, the Appeals Office concluded
that respondent’s determination to proceed with collection by way
of levy should be sustained.
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Last modified: May 25, 2011