Joseph T. Tornichio - Page 5




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          attempted to challenge his underlying tax liability and demanded            
          proof of his tax assessments, copies of Form 4340 (Certificate of           
          Assessments, Payments, and Other Specified Matters), copies of              
          his tax returns for the years at issue, and verification that all           
          applicable laws and administrative procedures had been followed             
          in the assessment and collection process.                                   
          E.  Respondent’s Notice of Determination                                    
               On November 1, 2001, respondent sent petitioner a Notice of            
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330.  In the notice of determination, the Appeals Office            
          concluded that the proposed collection action should be                     
          sustained.                                                                  
          F.  The Petition                                                            
               On December 4, 2001, petitioner filed his petition with this           
          Court seeking review of respondent’s notice of determination.               
          The petition includes allegations that:  (1) The Appeals officer            
          failed to properly verify that the requirements of any applicable           
          law or administrative procedure were met as required under                  
          section 6330(c)(1); (2) petitioner did not receive the requisite            
          statutory notice and demand for payment or valid notice of                  
          deficiency; and (3) petitioner was denied the opportunity to                



               2(...continued)                                                        
               Revenue Code with that section marked liability for                    
               tax.  If you could show me the statute that requires me                
               to pay the tax, I am prepared to make arrangements to                  
               pay that which you say that I owe.                                     




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