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forth therein, plus penalties and interest. See Aguirre v.
Commissioner, 117 T.C. 324 (2001).
Additional Issues
1. Impartiality of the Appeals Officer
Petitioner raises other issues not considered in the
District Court case, including a claim that section 6330(b)(3)
and (c)(2)(A) was violated because the Appeals officer was
instructed not to consider his claims concerning the failure of a
Form 23C to be provided or considered. As previously noted, a
Form 23C is not necessary to establish the validity of the
assessments. Accordingly, an instruction to the Appeals officer
to refuse to consider petitioner’s “Form 23C” arguments, which
are based solely on the premise that a Form 23C is indispensable
to a valid assessment, does not violate petitioner’s right to
raise “any relevant issue” relating to the proposed levy under
section 6330(c)(2)(A). Similarly, the instruction did not cause
the Appeals officer not to be “impartial” within the meaning of
section 6330(b)(3). The operative terms of section 6330(b)(3)
indicate that “impartial” as used in the heading of that
provision concerns the Appeals officer’s prior involvement with
respect to the unpaid tax before the hearing.7 In sum, neither
7 Sec. 6330(b)(3) provides as follows:
SEC. 6330(b). Right to Fair Hearing.
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