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laws and administrative procedures were followed with regard to
the assessment and collection of the tax liability in question.
D. The Appeals Office Hearing
On April 11, 2001, petitioner attended an administrative
hearing in Las Vegas, Nevada, conducted by Appeals Officer Lavada
Harmon (the Appeals officer). Following the hearing, the Appeals
officer prepared an Appeals Office memorandum which recited that
petitioner did not raise any valid issue during the hearing and
that the Appeals officer informed petitioner of the Court’s
opinion in Pierson v. Commissioner, 115 T.C. 576 (2000). The
Appeals office memorandum also stated that the Appeals officer
concluded that all administrative and procedural requirements
were followed with regard to the assessment and collection of the
tax liability in question.
The record in this case includes a literal “plain English”
transcript of petitioner’s account for the taxable year 1997,
dated February 6, 2001, as well as a Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters, dated
September 12, 2001. Both documents were attached to respondent’s
motion for summary judgment, which was served on petitioner.
E. Respondent’s Notice of Determination
On July 16, 2001, respondent’s Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 with regard to his tax
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