- 5 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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