Lionel D. Kolker - Page 5

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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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