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verification of legal and procedural requirements, however, the
attachments refer twice to petitioner’s 1998 tax year and once to
petitioner’s 1998 account. Petitioner seizes upon these
misstatements as establishing the invalidity of the notices of
determination and infirmities in the administrative process.
When read in the context of other information in the
notices, which makes it clear that the notices relate to
petitioner’s 1992 tax year, and of other materials in the
administrative file, the references to petitioner’s 1998 tax year
are plainly typographical errors, as Appeals Officer Cody
declares in her affidavit, which is in evidence.10
The evidence shows that Cody reviewed, among other things,
respondent’s final notice of intent to levy, the transcripts of
petitioner’s account, and the case history leading up to the
collection action in question. Her review of the transcripts and
other materials satisfies the section 6330(c)(1) requirement that
the hearing officer “obtain verification from the Secretary that
the requirements of any applicable law or administrative
10 For instance, the attachment to each notice of
determination states: “IDRS shows an assessment of tax, penalty
and applicable interest made on the 1998 tax period”. The next
sentence, however, states: “This assessment was made on
10/16/1995.” This latter date corresponds with the date that
petitioner was sent the statutory notice of balance due for his
1992 taxes, as indicated by the plain-language transcript of
petitioner’s 1992 account that is in evidence.
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