George A. Robinson - Page 6




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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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