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Process hearing expressly referenced the final notice of intent
to levy.
E. The Appeals Office Hearing
On January 16, 2002, petitioner attended an administrative
hearing conducted by an Appeals officer at the IRS Appeals Office
in Toledo, Ohio.
At the start of the hearing, the Appeals officer stated that
because petitioner’s request for an administrative hearing was
received more than 30 days after the issuance of the final notice
of intent to levy (and, a fortiori, more than 30 days after the
issuance of the notice required by section 6320), the hearing
would be conducted as an “equivalent” hearing.
During the hearing, petitioner requested that the Appeals
officer verify that the persons who issued the final notice of
intent to levy and the notice required by section 6320 and who
filed the Notice of Federal Tax Lien were all authorized to do
so. Petitioner also questioned the validity of the final notice
of intent to levy because it was not signed.
F. Respondent’s Decision Letter
On July 12, 2002, the Appeals Office issued to petitioner a
Decision Letter Concerning Equivalent Hearing Under Section 6320
and/or 6330 (the decision letter) with regard to petitioner’s
unpaid tax liabilities for 1996 and 1997. In the decision
letter, the Appeals Office concluded: “The collection actions,
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