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collection action is proper and should be pursued
as was recommended by Collection for the income tax
liability.
• It is Appeals determination that normal collection
activity balances efficient collection with any
concerns you may have regarding the intrusiveness
of the action.
On April 23, 2001, the date on which petitioner filed the
petition in this case, petitioner filed a motion to dismiss for
lack of jurisdiction (petitioner’s motion to dismiss for lack of
jurisdiction) on the ground that the Appeals Office did not hold
a hearing with him.
On December 18, 2001, the Court issued an Order denying
petitioner’s motion to dismiss for lack of jurisdiction. That
was because, after petitioner filed petitioner’s motion to
dismiss for lack of jurisdiction, the Court overruled Meyer v.
Commissioner, 115 T.C. 417 (2000), and held that the Court will
not look behind a notice of determination to determine whether
the Appeals Office conducted a hearing. Lunsford v. Commis-
sioner, 117 T.C. 159, 164 (2001).
On December 2, 2002, respondent’s counsel provided petitioner
with Form 4340, Certificate of Assessments, Payments, and Other
Specified Matters (Form 4340), with respect to each of his
taxable years 1987, 1988, 1989, 1993, 1994, 1995, and 1996.
Discussion
Jurisdictional Matter
Respondent submitted to the Court a document entitled “MOTION
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