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obtained coded and noncoded (so-called “plain English”) versions
of computer-generated transcripts (transcripts) of respondent’s
records with respect to petitioner. Those transcripts identified
petitioner, the type of tax assessed, the taxable period, the
date of the assessment, and the amount assessed. At the Appeals
Office hearing, the Appeals officer relied on the transcripts for
the purpose of verifying that respondent made a valid assessment
with respect to petitioner’s taxable year 1995. The Appeals
officer provided to petitioner a copy of the plain English
version of those transcripts at the Appeals Office hearing.
On October 30, 2000, the Appeals Office issued to petitioner
a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER
SECTION 6320 and/or 6330" (notice of determination). That notice
stated in pertinent part:
(1) The only legal requirements before taking general
enforcement action are the notice & demand and the
notice of intent to levy and the notice of right to a
collection due process hearing. The assessments were
made, and notice & demand for payment, under
IRC6303(a), were sent to your last known address, along
with Publication 1, your rights as a taxpayer. You
neglected or refused to pay the taxes and penalties
due. Subsequently, you were sent the LT11 dated
4/28/2000. The Automated Collection System followed
all legal & procedural requirements and the action
proposed is appropriate under the circumstances, with
regard to the income tax due for 1995 only.
(2) The issues raised by you on your request are that,
for the income tax due for 1995, you did not earn the
alleged taxable income. For the Civil Penalties for
1996 & 1997, that the penalty is not based on agency
records. With regard to the income tax due for 1995,
the tax was assessed via a tax return filed by you on
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