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the years in issue, and she verified that all applicable laws and
administrative procedures had been met. Appeals Officer Jenkins
also provided petitioner copies of his transcripts of account for
the years in issue. Appeals Officer Jenkins provided petitioner
several opportunities to raise issues other than the delegation
of authority, including collection alternatives (such as an
installment agreement or an offer-in-compromise). Petitioner
stated that he was not interested in discussing collection
alternatives and that he wanted to terminate the hearing.
Respondent acceded to petitioner’s wishes, and the hearing ended.
On March 18, 2002, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) to petitioner regarding his
1996, 1997, and 1998 tax years. In the notice of determination,
respondent determined that (1) prior to the filing of the tax
lien, all statutory, administrative, and procedural requirements
had been met, (2) no viable collection alternatives were
established, and (3) the tax lien was not considered to be overly
intrusive.
On March 27, 2002, respondent mailed petitioner certified
certificates of assessments, payments, and other specified
matters for the years in issue.
On April 1, 2002, petitioner timely filed an imperfect
petition for lien or levy action under Code section 6320(c) or
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Last modified: May 25, 2011