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petitioner’s response by May 9, 2002. Petitioner responded in a
letter to Ms. Dodson dated April 30, 2002. Although several
exhibits were attached to the letter, none of the exhibits
supplied the information requested by Ms. Dodson. Petitioner’s
April 30, 2002, letter demanded that respondent pay her “all
allowances, credits, standard deductions, benefits 1993 through
2001.”
On May 9, 2002, the Appeals Office issued a Notice of
Determination Concerning Collection Action(s) under Section 6320
and/or 6330 in which it determined the following:
1. All legal and procedural requirements for the issuance
of the Notice of Intent to Levy had been met.
2. Prior to the Appeals officer’s consideration of the
issues raised by petitioner, the Appeals officer had had no
previous involvement with respect to petitioner’s 1993 and 1994
income tax liabilities.
3. None of the issues raised by petitioner were
meritorious.
4. Petitioner did not raise any spousal defenses.
5. Petitioner was not entitled to challenge the underlying
liabilities for 1993 and 1994 because she had received notices of
deficiency for those years.
6. The proposed levy action balanced the need for efficient
collection of taxes with the legitimate concern of the taxpayer
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