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C. Respondent’s Final Notice and Petitioner’s Response
On March 8, 2001, respondent sent petitioner a Final
Notice-–Notice of Intent to Levy and Notice of Your Right
to a Hearing (the Final Notice). The Final Notice, issued in
respect of petitioner’s outstanding tax liabilities for 1996 and
1998, was signed by Scott Kilpatrick, identified as the Chief of
the Automated Collection Branch in Ogden, Utah. On March 16,
2001, petitioner submitted to respondent a Form 12153, Request
for a Collection Due Process Hearing. Petitioner’s request
stated that he was challenging the validity of the assessments
for 1996 and 1998 on the grounds there is no statute imposing tax
liability upon him and he was not served with a valid notice and
demand for payment.
D. The Appeals Office Hearing
On October 9, 2001, Appeals Officers Tony Aguiar and Julie
Peterson (the Appeals officers) conducted an Appeals Office
hearing that petitioner attended. According to a purported
transcript of the hearing prepared by petitioner, the Appeals
officers provided petitioner with Forms 4340, Certificate of
Assessments, Payments, and Other Specified Matters, with regard
to petitioner’s accounts for the years 1996 and 1998. Copies of
the Forms 4340, dated September 4, 2001, are attached to the
petition that petitioner filed with the Court. During the
hearing, petitioner declined to discuss collection alternatives.
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