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Petitioner also contends that he was not given a hearing as
required by section 6330. Respondent contends that the Appeals
officer scheduled a hearing and provided petitioner with written
notice of the hearing. Petitioner has not contended that he did
not receive notice of the scheduled hearing. Petitioner did not
attend the scheduled hearing and did not attempt to reschedule
the hearing. The Court agrees with respondent that petitioner
was granted an opportunity for a hearing. Accordingly, we hold
that respondent’s determination to proceed with the levy is not
an abuse of discretion.
Issue 2. Section 6673(a)(1) Penalty
We decline to impose a penalty under section 6673(a)(1).
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
An appropriate order will be
issued, and decision will be
entered for respondent.
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Last modified: May 25, 2011