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procedure have been met”. See, e.g., Yacksyzn v. Commissioner,
T.C. Memo. 2002-99.
In the attachment to each notice of determination, Appeals
Officer Cody states: “I have had no prior involvement with this
taxpayer concerning the 1998 tax period before this CDP case.”
On the basis of this statement, which misstates the tax period in
question, petitioner alleges that respondent failed to show that
the Appeals officer was “impartial” with respect to this
collection proceeding as required by section 6330(b)(3). As
previously indicated, we attach little significance to the
typographical error regarding the tax period in question. For
purposes of section 6330(b)(3), an “impartial” officer is one
“who has had no prior involvement with respect to the unpaid tax
specified in subsection (a)(3)(A) before the first hearing under
this section or section 6320.” See Perez v. Commissioner, T.C.
Memo. 2002-274. Petitioner has presented no evidence that
Appeals Officer Cody was previously involved in his case. We
conclude that the section 6330(b)(3) impartiality requirement was
satisfied in this case.
V. Conclusion
Petitioner has not made a valid challenge to the
appropriateness of the proposed collection action or offered any
collection alternatives. The Appeals officer did not act in an
arbitrary or capricious way, or in an unlawful or unreasonable
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