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arguments. Petitioner stated that he had not completed Form 433-
A but that he was interested in resolving the collection issue.
Although petitioner produced documentation to show that he had
timely requested a hearing pursuant to section 6330, petitioner
raised no other relevant issue and presented no evidence to prove
either that he did not owe the 1993 liability, that the 1993
liability had been paid, or that a collection alternative was
appropriate. Instead, petitioner and a “friend” whom he had
brought to the hearing pressed Ms. Chadwell to discuss whether
petitioner had an “obligation” to file a return and pay tax.
When petitioner and his friend refused to discuss collection
alternatives, Ms. Chadwell terminated the hearing.
Respondent subsequently issued a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330,
dated March 3, 2004, which sustained the proposed levy action.
In the notice of determination, respondent concluded that
petitioner had not raised any valid issue regarding the merits of
the underlying tax liability or the appropriateness of the
proposed levy action and determined that all of the requirements
imposed by section 6330 for a valid levy had been satisfied. In
the notice of determination, respondent concluded that the
proposed levy balanced the need for the efficient collection of
tax with the concern that the collection action be no more
intrusive than necessary, warned petitioner that this Court was
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