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FINDINGS OF FACT
Most facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the accompanying
exhibits. Petitioner resided in Artesia, New Mexico, at the time
his petition was filed with the Court.
In a letter dated September 13, 1999, respondent mailed a
“Final Notice - Notice of Intent to Levy and Notice of Your Right
to a Hearing” to petitioner with respect to Federal income taxes.
The September 13 notice informed petitioner of (1) respondent’s
intention to levy under section 6331 and (2) petitioner’s right
to Appeals Office consideration. Additionally, enclosed with the
notice was a copy of Form 12153, Request for a Collection Due
Process Hearing, to request a hearing with the Appeals Office.
On October 12, 1999, pursuant to section 6330(a), petitioner
timely requested a hearing using the Form 12153. In the request
for a hearing, petitioner questioned the existence of a “valid
summary record of assessment pursuant to 26 CFR � 301.6203-1.”
On March 29, 2000, respondent mailed to petitioner a letter
stating that it was the Appeals officer’s “determination that * *
* [petitioner’s] reasons for disagreeing with the proposed
enforcement actions are frivolous and without merit” and
scheduling a hearing for April 19, 2000. Petitioner did not
attend the scheduled hearing and did not contact the Appeals
officer to reschedule the hearing.
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