Johnny Owings Milam, Jr. and Brenda Ramsey Milam - Page 4

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               deficient on it’s [sic] face because it is not in                      
               compliance with 26 USC section 6065.                                   
               A face-to-face meeting was held between petitioners and an             
          Appeals officer on August 22, 2001.  On November 5, 2001, the               
          Appeals officer issued a Notice of Determination Concerning                 
          Collection Action(s) Under Section 6320 and/or 6330, wherein he             
          determined:  (1) That the requirements of all laws and                      
          administrative procedures had been met; (2) that petitioners had            
          had a prior opportunity to dispute the underlying tax liability             
          and were thus precluded from contesting it in the collection                
          proceeding; and (3) that no other issues had been raised.  Based            
          on these findings, the Appeals officer determined that the lien             
          was appropriate.                                                            
               On January 31, 2002, petitioners filed their petition in the           
          instant case.  The petition raises several issues, including:               
          (1) Whether “procedurally proper” versions of various documents             
          were ever issued, including a notice of deficiency, a notice and            
          demand for payment, and a notice of Federal tax lien; (2) whether           
          petitioners’ liabilities were properly assessed; (3) whether the            
          Appeals officer failed to verify that the requirements of any               
          applicable law or administrative procedure were met, as required            
          by section 6330(c)(1); and (4) whether respondent erred by                  
          failing to allow petitioners an examination interview and an                
          administrative appeal prior to issuance of the notice of                    







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