Ted L. Williams - Page 3




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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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