Andy Hromiko - Page 4

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          Trust was pending before the Court of Appeals for the Ninth                 
               A face-to-face meeting was held between petitioner and an              
          Appeals officer of respondent on August 16, 2002.  On August 30,            
          2002, respondent issued to petitioner a Notice of Determination             
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          (notice of determination).  The notice of determination states:             
               He [petitioner] wanted to see the physical documents                   
               that created the assessments.  I told him that I had                   
               ordered a form 4340, Certificate of Official Record.                   
               This is sufficient proof for the Courts to show the                    
               assessment was properly made.  Once this is received, I                
               will mail him a copy and keep the originals in the file                
               for the case record.                                                   
               Was the action legally and procedurally correct?                       
               I have reviewed the administrative file and the                        
               transcripts of the liability and determined that the                   
               proposed levy was legally and procedurally correct.                    
               The Appeals officer also concluded that respondent was not             
          barred from collecting prior to the disposition of petitioner’s             
          appeal because petitioner had not filed a bond as required by               
          section 7485(a).                                                            
               Petitioner filed a timely petition for review of                       
          respondent’s determination.  The only issue raised in the                   
          original petition was that collection was inappropriate because             
          petitioner had filed an appeal with respect to the underlying tax           
          liability that was pending before the Court of Appeals for the              

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