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requirements of any applicable law or administrative procedure
have been met”, for example, a copy of the statutory notice and
demand for payment; (2) a copy of Form 23C, Summary Record of
Assessment, and the “pertinent parts of the assessment which set
forth the name of the taxpayer, the date of the assessment, the
character of the liability assessed, the taxable period, and the
amount assessed”; (3) delegation of authority from the Secretary
to the person (other than the Secretary) who signed the
verification required under section 6330(c)(1); and (4) proof
that notices of deficiency were sent to petitioner.
C. The Section 6330 Hearing and Respondent’s Notice of
Determination
On December 28, 1999, respondent’s Appeals Office conducted
a hearing in petitioner’s case for tax years 1990-97. Petitioner
attended the hearing. He was not given an opportunity to
challenge his underlying tax liability for 1990-97 at the
hearing. At the hearing, he asked the Appeals officer to provide
verification that the requirements of any applicable law or
administrative procedures had been met, to give him copies of a
notice and demand for payment, and to show him “anything that
indicated [he] owed income tax” or that he was required to pay
Federal income tax. The Appeals officer did not comply with
petitioner’s requests and told petitioner that the hearing was
limited to alternatives to collection. At the hearing,
petitioner did not challenge the appropriateness of the intended
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Last modified: May 25, 2011