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6673(a) for making frivolous and groundless arguments in a
collection review proceeding.
E. Respondent’s Notice of Determination
On May 7, 2002, respondent’s Appeals Office mailed to
petitioner, at his Las Vegas address, a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
with regard to his tax liability for 1998. In the notice, the
Appeals Office concluded that respondent’s determination to
proceed with collection should be sustained.
F. Petitioner’s Petition
On June 10, 2002, petitioner filed with the Court a Petition
for Lien or Levy Action seeking review of respondent’s notice of
determination. In the petition, petitioner identified his Las
Vegas address as his current address, and he attached as exhibits
a number of documents, including the notice of determination (see
supra “E”).
The petition includes allegations that: (1) The Appeals
officer failed to obtain verification from the Secretary that the
requirements of any applicable law or administrative procedure
were met as required under section 6330(c)(1); (2) the Appeals
officer failed to identify the statutes making petitioner liable
for Federal income tax; (3) petitioner never received a “valid”
notice of deficiency; (4) petitioner never received a “statutory”
notice and demand for payment; and (5) petitioner was denied the
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