Andy Hromiko - Page 5

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          Ninth Circuit.  Petitioner subsequently amended the petition to             
          allege that the Appeals officer had failed, as required by                  
          section 6330(c)(1), to verify that all applicable laws and                  
          administrative procedures had been met; in particular, petitioner           
          alleged that the liabilities had not been properly assessed and             
          that he had not received notice of the assessments as required by           
          section 6303.                                                               
               Subsequent to the filing of respondent’s motion for summary            
          judgment and petitioner’s response, the Court of Appeals on                 
          February 14, 2003, affirmed our opinion in MatrixInfoSys Trust v.           
          Commissioner, supra, sustaining the underlying tax liabilities              
          that are the subject of this collection action, and entered                 
          judgment.  Hromiko v. Commissioner, 56 Fed. Appx. 359 (9th Cir.             
               Section 6331(a) provides that if any person liable to pay              
          any tax neglects or refuses to pay such tax within 10 days after            
          notice and demand, the Secretary may collect such tax by levy on            
          the person’s property.  Section 6331(d) provides that at least 30           
          days before enforcing collection by levy on the person’s                    
          property, the Secretary must provide the person with a final                
          notice of intent to levy, including notice of the administrative            
          appeals available to the person.                                            

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