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OPINION
I. Petitioner’s Contentions
In his petition, petitioner raises numerous technical and
procedural complaints about respondent’s determination to proceed
with collection action. Petitioner filed no posttrial brief. In
his pretrial memorandum, petitioner distilled his complaints into
these three issues: (1) Whether the Appeals Office failed to
offer petitioner the hearing that he requested pursuant to
section 6330(b)(1); (2) whether this Court may redetermine his
1992 underlying income tax liability; and (3) whether the notices
of determination are invalid because they contain some incorrect
references to petitioner’s 1998 tax year and account.7
II. Whether the Appeals Office Failed To Offer Petitioner a
Hearing
If a taxpayer fails to pay any Federal tax liability within
10 days of notice and demand, the Secretary is authorized to
collect the tax by levy on the taxpayer's property. Sec.
6331(a). At least 30 days before taking collection action, the
Secretary must provide the taxpayer with a final notice of intent
to levy that describes, among other things, the availability of
administrative appeal. Sec. 6331(d).
7 We have carefully considered all issues raised in the
petition. We construe most of them as falling within the ambit
of the three issues identified above, and we address them in that
context. The other issues raised in the petition are without
merit, moot, or irrelevant; in any event, we deem petitioner to
have abandoned such other issues.
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Last modified: May 25, 2011