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May 2, 2002 and forward. Therefore you [sic] request
to tape record and/or bring a court reporter * * * is
denied.
On August 29, 2002, a settlement officer held an Appeals
Office hearing with petitioner George R. Kemper (Mr. Kemper) with
respect to the notice of intent to levy.6 At the Appeals Office
hearing, the settlement officer gave Mr. Kemper Form 4340,
Certificate of Assessments, Payments, and Other Specified Matters
(Form 4340), with respect to each of petitioners’ taxable years
1995, 1996, 1997, and 1998.
On September 26, 2002, the Appeals Office issued a notice of
determination concerning collection action(s) under section 6320
and/or 6330 (notice of determination) to Mr. Kemper and a sepa-
rate notice of determination to Ms. Kemper. (We shall refer
collectively to those two notices as petitioners’ notices of
determination.) An attachment to each such notice of determina-
tion stated in pertinent part:
Verification of Legal and Procedural Requirements
The Secretary has provided sufficient verification that
all legal and procedural requirements have been met.
Appeals has reviewed computer transcripts verifying the
assessment.
Assessments were made and the taxpayer was issued
notice and demand letters by regular mail, to the
taxpayer’s last known address, as required under IRC
6303. He neglected or refused to pay. The notices
required under IRC 6331(d) and IRC 6330 were combined
6Petitioner Karen S. Kemper (Ms. Kemper) did not appear at
the Appeals Office hearing held on Aug. 29, 2002.
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