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Appeals Office (settlement officer) held an Appeals Office
hearing with petitioner Michael D. Keown (Mr. Keown)4 with re-
spect to the notice of intent to levy. At the Appeals Office
hearing, the settlement officer gave Mr. Keown Form 4340, Certif-
icate of Assessments, Payments, and Other Specified Matters, with
respect to petitioners’ taxable year 1999.
On September 12, 2002, the Appeals Office issued a notice of
determination concerning collection action(s) under section 6320
and/or 6330 (notice of determination) to Mr. Keown and a separate
notice of determination to Ms. Keown. (We shall refer collec-
tively to those two notices as petitioners’ notices of determina-
tion). An attachment to each such notice of determination stated
in pertinent part:
What is the Issue?
The taxpayers requested a hearing under the provisions
of IRC 6330 to contest the intent to levy notice,
Letter LT-11.
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.
An assessment was made and the taxpayers were issued
notice and demand letters by regular mail, to the
taxpayers’ last known address, as required under IRC
6303. They neglected or refused to pay. The notices
required under IRC 6331(d) and IRC 6330 were combined
4Petitioner Rosann C. Keown (Ms. Keown) did not appear at
the Appeals Office hearing held on Aug. 28, 2002.
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