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her 1996, 1997, 1998, 1999, and 2000 tax years (hearing
request).2
Petitioner attended an Appeals Office hearing (hearing) with
Appeals Officer J.A. Vander Linden. The Appeals officer reviewed
petitioner’s administrative file and transcripts of account for
the years in issue. At the hearing, petitioner raised only
frivolous issues and arguments.
On March 22, 2002, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 to petitioner regarding her 1996, 1997, and 1998 tax
years (notice of determination). In the notice of determination,
respondent determined that the Federal Tax Lien should remain in
place.
On April 22, 2002, petitioner timely filed a petition for
lien or levy action under Code section 6320(c) or 6330(d) seeking
review of respondent’s determination to proceed with collection
of petitioner’s 1996, 1997, and 1998 tax liabilities.
On November 6, 2002, respondent filed a motion for summary
judgment and to impose a penalty under section 6673. Attached as
exhibits to the motion for summary judgment are literal
transcripts and computer generated transcripts (TAXMODA) of
2 On Sept. 6, 2002, we dismissed for lack of jurisdiction
the portions of the petition that related to the sec. 6702
frivolous return penalties for 1996 through 1999 and the sec.
6682 false withholding information penalty for 2000.
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