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judgment, petitioner renews this claim, arguing that it
constitutes a genuine issue of material fact. Respondent admits
that no assessment certificate was included with the Notice of
Intent to Levy; accordingly, no issue of fact arises. Respondent
further points out, however, that copies of Forms 4340 covering
1995, 1996, and 1997 were mailed to petitioner on July 25, 2001.
Petitioner’s argument that the failure to provide assessment
certificates with the Notice of Intent to Levy invalidates the
levy or otherwise deprives him of rights to which he is entitled
has no merit. There is no requirement that a certificate of
assessment be provided with a levy notification. Sections 6330
and 6331, which establish requirements for information to be
included with a notice of levy, make no mention of an assessment
certificate or other proof of assessment as an item of
information to be so included. Respondent treated petitioner’s
reference in his hearing request to his rights under section
301.6203-1, Proced. & Admin. Regs., as constituting a request for
a copy of the record of assessment for the liabilities sought to
be collected. Respondent provided Forms 4340 in response thereto
on July 25, 2001. Thus, there is no showing of any violation of
petitioner’s rights under section 6203. Further, petitioner was
offered a hearing through either a face-to-face meeting or by
means of correspondence and did not avail himself of either
opportunity.
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