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6212 and 6213, since I have not been able to locate
them.
Without your furnishing me with these documents
and information, I will be unable to “ascertain” * * *
whether the individual who sent me the Deficiency
Notice was authorized to do so, and whether I am le-
gally required to take any notice of it. * * *
[Reproduced literally.]
On January 8, 2001, respondent assessed petitioner’s tax, as
well as any penalties and interest as provided by law, for each
of his taxable years 1997 and 1998. (We shall refer to those
assessed amounts, as well as interest as provided by law accrued
after January 8, 2001, as petitioner’s unpaid liabilities for
1997 and 1998.)
On January 8, 2001, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid liabilities
for 1997 and 1998.
On August 14, 2001, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to his taxable years 1997
and 1998. On or about September 10, 2001, in response to the
notice of intent to levy, petitioner filed Form 12153, Request
for a Collection Due Process Hearing (Form 12153), and requested
a hearing with respondent’s Appeals Office (Appeals Office).
Petitioner attached a document to his Form 12153. That document
stated in pertinent part:
I am requesting a “Due Process Hearing” as out-
lined in From 12153. I am “challenging the appropri-
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