Michael W. Bethea - Page 4

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          balance due.  An additional notice of balance due was sent on               
          May 22, 2000.                                                               
               On July 29, 2000, respondent issued to petitioner a Final              
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing with respect to the unpaid liabilities for 1997.                    
          Petitioner returned to respondent a completed and signed Form               
          12153, Request for a Collection Due Process Hearing, with an                
          attachment in which he disputed, among other things, his receipt            
          and/or the validity of the underlying tax liability, the notice             
          of deficiency, the assessment, and the notice and demand for                
          payment.                                                                    
               A hearing was conducted on March 19, 2002.  Both prior to              
          and at the hearing, petitioner was provided with copies of Form             
          4340, Certificate of Assessments, Payments, and Other Specified             
          Matters.  Petitioner’s arguments at the hearing challenged the              
          collection action on grounds of liability, claiming a lack of               
          authority on the part of the Internal Revenue Service to assess             
          and collect the tax.  Following the hearing, on March 29, 2002,             
          respondent issued to petitioner the Notice of Determination                 
          Concerning Collection Actions(s) Under Section 6320 and/or 6330             
          sustaining the proposed levy.                                               
               Petitioner’s petition disputing respondent’s notice of                 
          determination was filed on April 29, 2002, and reflected an                 
          address in Fort Walton Beach, Florida.  The petition raises                 






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