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Petitioner did not submit financial information on a Form 433-A,
stating: “With regard to Appeals considering collection
alternatives, this will not be necessary. I elect to make
payment in full if a determination which is based upon
requirements of law and administrative procedure shows that an
amount is due and owed”.
On May 13, 2003, petitioner attended a scheduled face-to-
face meeting with the settlement officer. At the hearing,
petitioner requested that she be permitted to audio record her
hearing. Her request was denied.
On July 9, 2003, respondent issued to petitioner a Notice of
Determination Concerning Collection Action(s) under Section 6320
and/or 6330 (notice of determination). In the notice of
determination, the settlement officer determined that it was
appropriate for respondent to proceed with the proposed levy to
collect petitioner’s tax liability. In regard to issues
discussed at the hearing, the settlement officer wrote:
You stated, at the hearing, that you know of no section
of the Internal Revenue Code, which requires you to pay
the tax. You also state that, despite admitted gross
income in 1996 no authority is authorized to assess
you. A discussion of Internal Revenue Code Sections 1,
61 and 63 took place at the hearing. * * *
* * * * * * *
No valid issues were raised. Throughout this
proceeding you disputed the legal basis and procedures
relating to the 1996 obligation. You have not taken a
significant or positive step to resolve the 1996
delinquency. Your issues are without foundation. No
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