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Respondent did not hold an Appeals Office hearing with
petitioner. That is because the Appeals officer determined that
the matters advanced in petitioner’s attachments to Forms 12153
did not require respondent to hold a hearing to discuss those
matters. The Appeals officer did advise petitioner in a letter
(Appeals officer’s September 5, 2000 letter) that she was willing
to examine any information that petitioner wished to submit
showing that petitioner is not liable for the unpaid liabilities
at issue, requesting an installment agreement, or requesting an
offer in compromise. Petitioner did not provide any information
in response to the Appeals officer’s September 5, 2000 letter.
On March 22, 2001, the Appeals Office issued to petitioner a
notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). The notice
of determination pertains to petitioner’s taxable years 1987,
1988, 1989, 1993, 1994, 1995, and 1996. An attachment to the
notice of determination stated in pertinent part:
MATTERS CONSIDERED AT THE APPEALS HEARING
Applicable Law and Administrative Procedures
• With the best information available, the require-
ments of various applicable law and administrative
procedures have been met.
• Internal Revenue Code Section 6331(d) requires that
4(...continued)
e.g., Copeland v. Commissioner, supra; Smith v. Commissioner,
supra.
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Last modified: May 25, 2011