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the IRS notify a taxpayer at least 30 days before a
Notice of Levy can be issued. A transcript of your
account verifies that this notice was issued.
• Internal Revenue Code Section 6330(a) states that
no levy may be made unless the IRS notifies a tax-
payer of the opportunity for a hearing with the IRS
Office of Appeals. This notice was sent to you via
certified mail.
• You were given the opportunity to raise any rele-
vant issue relating to the unpaid tax or the Notice
of Intention to Levy in accordance with Internal
Revenue Code Section 6330(c).
• This Appeals Officer has had no prior involvement
with respect to these liabilities.
Relevant Issues Presented by the Taxpayer
• You contend that you are not liable for tax and you
don’t owe anything because you are not a taxpayer
and therefore, not required to file.
• You also stated that you never received the statu-
tory notice and demand for payment nor did you
receive a (valid) notice of deficiency.
• You failed to raise any issues that could be con-
sidered in a due process hearing pursuant to Inter-
nal Revenue Code Section 6330. Our review of your
file indicates a hearing is not available for con-
stitutional issues such as those referenced in your
reply to the final notice.
• You can not challenge the tax liabilities for 1987,
1988, 1989, 1993, 1995 [sic] and 1995 because you
did received [sic] a deficiency notice. You did
not avail yourself of the opportunity to file a
petition for redetermination with the court.
• Appeals believes that you are liable for the income
tax liabilities for tax years 1987, 1988, 1989,
1993, 1994 and 1995 in accordance with the law.
Balancing Efficient Collection and Intrusiveness
• It is Appeal’s determination that the proposed
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Last modified: May 25, 2011