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section 6320 and/or 6330 (supplemental notice of determination),
which the Appeals Office mailed to petitioner on May 1, 2003,
after petitioner filed the petition in this case. That supple-
mental notice, which pertained to petitioner’s taxable years
1990, 1991, 1992, 1993, and 1996, stated in pertinent part:
Summary of Determination
The Internal Revenue Service mailed a Letter 1058,
Final Notice - Notice Of Intent To Levy And Notice Of
Your Right To A Hearing, on March 7, 2001 concerning
the unpaid Federal income tax (Form 1040) for the
periods ending noted above [taxable years 1990, 1991,
1992, 1993, and 1996]. In response to the letter you
submitted Form 12153, received April 2, 2001, request-
ing a Collection Due Process Hearing. Your request was
forwarded to this Appeals Office.
Since you did not respond to the Appeals Officer’s
request for information nor attend the scheduled con-
ference on October 9, 2001, this office issued a Notice
of Determination. We are returning your case to the IRS
Area Counsel’s office for trial preparation.
An attachment to the supplemental notice of determination stated
in pertinent part:
Legal and Procedural Requirements
The Appeals Officer verified that the applicable laws
and administrative procedures have been met. IRC Sec.
6321 provides a statutory lien when a taxpayer neglects
or refuses to pay a tax liability after notice and
demand. Transcripts of the taxpayer’s accounts show
the Service Center issued notice and demand as follows:
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