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On April 22, 2002, respondent’s Appeals officer held an
Appeals Office hearing with petitioner with respect to the notice
of intent to levy. At the Appeals Office hearing, the Appeals
officer relied on Form 4340, Certificate of Assessments, Pay-
ments, and Other Specified Matters (Form 4340), with respect to
each of petitioner’s taxable years 1997 and 1998.
On May 7, 2002, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to the notice of determination stated in pertinent part:
The Secretary has provided you with sufficient verifi-
cation that the requirements of any applicable law or
administrative procedures have been met.
You requested a Collection Due Process Hearing under
IRC 6330 opposing levy action. Your Request for a
Collection Due Process was timely filed and you are
entitled to judicial review.
The case was assigned to Tony Aguiar, Appeals Officer,
who had no prior involvement with respect to the dis-
puted tax liability.
The levy notice reflects a liability for income taxes
owed for 1997 and 1998. Zero type income tax returns
were filed for 1997 and 1998. Statutory Notices of
Deficiency were sent to you for both years on August 3,
2000. You responded to the sent Statutory Notice of
Deficiency with your interpretation of the tax laws.
You were given an opportunity to petition the United
States Tax Court and choose not to. The Statutory
Notice of Deficiency defaulted and an assessment was
made. The assessment made is valid. The assessment
has been made and notice and demand letters were issued
by regular mail to your last known address as required
and demonstrated by forms 4340s in the administrative
file.
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Last modified: May 25, 2011