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1995, and 1996 and (2) an equivalent hearing with respect to
respondent’s February 5, 1999 notice of intent to levy concerning
Ms. Holguin’s taxable years 1994, 1995, and 1996.11 Prior to
those hearings, the Appeals officer gave Mr. Holguin Form 4340,
Certificate of Assessments, Payments, and Other Specified Mat-
ters, with respect to each of Mr. Holguin’s taxable years 1994,
1995, and 1996.
On April 30, 2002, the Appeals Office issued to Mr. Holguin
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). An attach-
ment to the notice of determination stated in pertinent part:
What are the Issues?
The taxpayer requested a hearing under the provisions
of I.R.C. section 6330 to contest the application of a
notice of intent to levy, Form 1058.
Verification of Legal and Procedural Requirements
The requirements of all applicable laws and administra-
tive procedures have been met:
The liabilities were assessed and notice and
demand letters were issued by regular mail to the
taxpayer’s last known address as required under I.R.C.
6303, demonstrated by the forms 4340 in the administra-
tive file;
There was an assessed liability and a levy source
determined by the Revenue Officer at the time the
notice of intent to levy was issued to TP;
The notices required under I.R.C. 6330 were pro-
vided to TP on the dates shown above in relation to the
levy notice, L-1058;
11Mr. Holguin represented Ms. Holguin at the equivalent
hearing held on Apr. 18, 2002.
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