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determination with respect to, inter alia, his taxable years 1987
and 1990. That notice stated in pertinent part as follows:
Summary of Determination:
The Notice of Federal Tax Liens were filed on
8/18/94 and are not subject to the Due Process Proce-
dures under IRC Section 6320.
With respect to the Notice of Intent to Levy,
there has been no response to requests for the comple-
tion of financial statements in order to determine if a
possible collection alternative is feasible. We are
sustaining the District’s decision to take appropriate
enforcement action.
* * * * * * *
Applicable Law and Administrative Procedures
With the best information available, the require-
ment [sic] of various applicable law or administrative
procedures have been met.
Notice and Demand was made for the above periods
as verified by review of the transcripts and revenue
officer history and correspondence.
IRC Section 6331(d) requires that the IRS notify a
taxpayer at least 30 days before a Notice of Levy can
be issued. The 30 day notice was mailed to the tax-
payer via certified mail and the return receipt was
signed.
IRC Section 6330(a) states that no levy may be
made unless the IRS notifies a taxpayer of the opportu-
nity for a hearing with the IRS Office of Appeals.
Letter 1058 “Final Notice” was sent to the taxpayer by
certified mail. The hearing was requested within the
appropriate time frames.
This appeals officer had no prior involvement with
respect to these liabilities.
Relevant Issues Presented by the Taxpayer
The attachment to Form 12153 referred to the
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