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On March 9, 2000, petitioner attended an Appeals Office
hearing in Cincinnati, Ohio, conducted by Appeals Officer William
C. Roll. On July 21, 2000, the Appeals Office mailed to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination). The notice of determination states in pertinent
part:
The assessments for 1986 are invalid, and no collection
action will be enforced.
For 1990, the assessments are valid. In your appeal,
you did not raise any alternative collection method to
enforce collection, and the proposed levy should be
enforced.
An attachment to the notice of determination states in pertinent
part:
A valid notice of deficiency [for 1990] was issued, and
assessments were made in accordance with legal and
procedural requirements. The deficiency notice was
mailed to your last known address, at the time the
notice was mailed. Your failure to file current
returns prevented an update of your address, so that
you failed to receive notices of demand for payment.
Your failure to receive the notices mailed to your last
known address does not invalidate the assessments. The
legal and procedural requirements for 1990 have been
met.
* * * * * * *
It is determined that a deficiency notice for 1990 was
mailed timely to your last known address. Your failure
to file any tax return after 1989, and failure to
cooperate in acknowledging your new address,
contributed to the lack of your current address being
in the files of the Internal Revenue Service. Because
notices were issued to your last known address as of
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