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sufficient to overcome the presumption of correctness
in regard to the existing signed Form 900.
On March 5, 2002, respondent mailed to petitioner a Notice
of Determination Concerning Collection Action(s) under Section
6320 and/or 6330 (the notice of determination) determining that
the tax assessments made against petitioner were valid and
appropriate, all requirements of various applicable law and
administrative procedures were followed, and issuance of the
notice of levy was appropriate given the facts and circumstances
presented by petitioner. In an attachment to the notice of
determination (“Attachment - 3193"), respondent rejected
petitioner’s claim that the extensions signed by him were
invalid:
Issue Raised by You
You state that you dispute the validity of the
collection statute extension. It was determined by our
office that there is no evidence to support your claim
that the extension to extend the collection statute of
limitations is invalid.
Discussion
I. Introduction
If any person liable for Federal tax liability neglects or
refuses to make payment within 10 days of notice and demand, the
Secretary is authorized to collect the tax by levy on that
person’s property. Sec. 6331(a). As a general rule, at least 30
days before taking such action, the Secretary must provide the
person with a written final notice of intent to levy that
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