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31, 2002, petitioner and Appeals Officer Isela H. Strong (Mrs.
Strong) agreed upon February 7, 2002, as the date for the
hearing. In a letter to petitioner dated February 1, 2002, Mrs.
Strong confirmed the hearing date and enclosed Form 656, Offer in
Compromise, and Form 433-A, Collection Information Statement for
Individuals. Petitioner did not return the forms.
On February 7, 2002, petitioner attended the hearing.
During the hearing, Mrs. Strong explained the purpose of the
hearing, provided petitioner the opportunity to raise any
relevant issues regarding his income tax liabilities, and asked
petitioner whether he was interested in alternative collection
methods. Petitioner argued that he did not owe taxes for 1997,
1998, and 1999 and refused to discuss alternative collection
methods.
On February 28, 2002, the Appeals Office issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 in which it determined the following:
1. All legal and procedural requirements for the issuance
of the Notice of Intent to Levy had been met.
2. Prior to the Appeals Officer’s consideration of the
issues raised by petitioner, the Appeals Officer had no previous
involvement with respect to petitioner’s 1997, 1998, and 1999
income tax liabilities.
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