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intrusive than necessary.
An attachment to the notice of determination stated in pertinent
part:
I. Applicable Law and Administrative Procedures.
On June 28, 2001, the Internal Revenue Service mailed a
Letter 11, FINAL NOTICE - NOTICE OF INTENT TO LEVY AND
NOTICE OF YOUR RIGHT TO A HEARING, concerning unpaid
Form 1040 for the periods [sic] ending December 31,
1997. In response to our letter you submitted Form
12153, received on July 17, 2001 requesting a Collec-
tion Due Process Hearing.
* * * * * * *
* * * Review of transcripts have confirmed the tax
was assessed, and notice and demand was mailed to the
taxpayer at his last known address, and there is still
a balance due.
* * * * * * *
* * * The record shows that such a notice was
mailed to you via certified mail, return receipt re-
quested, on June 28, 2001.
* * * * * * *
* * * The Appeals Officer assigned to hear your
case has had no prior involvement with respect to any
of your tax liabilities.
* * * * * * *
* * * You filed a timely protest and were provided
ample time and opportunity to schedule a face-to-face,
telephonic or correspondence hearing with the Appeals
officer, and to raise any relevant issues at such a
hearing. You declined to schedule a hearing, notwith-
standing the fact that a letter was sent to you on
October 16, 2001 at the address shown on your hearing
request and a second letter was sent to you on March
14, 2002 at the address shown on IRS records, confirmed
by you by phone on March 14, 2002. Other calls were
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