Curtis J.L. McIntosh - Page 3

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          with regard to his 1986, 1990, and 1991 tax liabilities.  This              
          notice was returned marked “No Longer At This Address/Addressee             
          Unknown”.                                                                   
               On September 22, 1993, respondent sent petitioner a Final              
          Notice (Notice of Intent to Levy) by certified mail to the Ohio             
          address.  On September 27, 1993, petitioner signed for the                  
          notice.  In October of 1993, petitioner’s address in respondent’s           
          master file was changed to the Ohio address after a collection              
          officer verified that the address was valid.                                
          C.  First Levy and Sale                                                     
               On July 24, 1995, respondent levied upon petitioner’s home             
          and vehicle (the property).  On October 6, 1995, respondent sold            
          the property by sealed bid to Alum Cliff Industries (ACI).                  
          Petitioner was never personally served with notice of the sale.             
          Respondent applied $10,583.24 of the sale proceeds to                       
          petitioner’s unpaid 1990 tax liability.                                     
          D.  Reversal of Sale and of Credit to Petitioner’s Tax Account              
               In 1995, petitioner brought suit in the U.S. District Court            
          for the Southern District of Ohio against various defendants,               
          including the Internal Revenue Service (IRS) and ACI.  See                  
          McIntosh v. United States, 82 AFTR 2d 98-6501 (S.D. Ohio 1998).             
          In this suit petitioner sought, among other things, to quiet                
          title to the property.  Admitting procedural irregularities in              
          failing to provide petitioner with notice of the sale of the                






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