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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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