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administrative procedures had been met. He also made the
determination required by section 6330(c)(3)(C) that the proposed
collection action (levy) balanced the need for efficient
collection of taxes with petitioner’s legitimate concerns that
any collection action be no more intrusive than necessary. On
December 5, 2001, a manager in the Appeals Office issued to
petitioner a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (i.e., the
determination), sustaining the proposed collection action.
In the petition, petitioner states his disagreement with the
assessments, claiming that they are inaccurate because of (1)
false and fraudulent information stated on the returns, (2)
errors in the assessment procedures, (3) reliance on incorrect
written advice from the IRS, (4) error and failure of the IRS in
following its own procedures and advice, (5) improper execution
of levies, and (6) erroneous and inconsistent tax information
contained in the determination.
Discussion
I. Overview of Section 6330
Section 6330 entitles a taxpayer to notice of the taxpayer’s
right to request a hearing before certain lien and levy actions
are taken by the Commissioner in furtherance of the collection
from the taxpayer of unpaid Federal taxes. If a hearing is
requested, the Appeals officer conducting the hearing must verify
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Last modified: May 25, 2011