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Appeals officer who conducted the administrative hearing.1 As
discussed in detail below, we shall deny petitioner’s Motion to
Dismiss.
Background
The record establishes and/or the parties do not dispute the
following:
A. Final Notice of Intent To Levy
On January 25, 2001, respondent sent to Rockie D. Elmore
(petitioner) and Leslie J. Elmore (together, the Elmores) a Final
Notice–Notice of Intent to Levy and Notice of Your Right to a
Hearing under section 6330 in respect of their outstanding tax
liability for 1998. The final notice of intent to levy was
issued by the Chief of the Automated Collection Branch in Austin,
Texas.
B. The Elmores’ Request for a Hearing
On February 14, 2001, the Elmores filed with respondent Form
12153, Request for a Collection Due Process Hearing, in respect
of their tax liability for 1998. The Elmores’ request for a
hearing stated that they were challenging the final notice of
intent to levy.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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