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In the attached memorandum, petitioner asserted he would
complete his delinquent returns within 60-90 days to prove that
he did not owe the tax liabilities determined by respondent.
In the attached memorandum, petitioner also stated he was
appealing Revenue Officer Angotta’s “levy warning letter” dated
February 14, 2000, which, according to petitioner, stated:
“Enforced collection may include placing a levy on your bank
accounts, wages, receivables, commissions, etc.”6 In the
attached memorandum, petitioner asserted: “Mr Angotta informed
me over the telephone that I have until March 15, 2000 to appeal
this action.”
In the attached memorandum, petitioner also said Revenue
Officer Angotta failed to respond to petitioner’s messages left
on Revenue Officer Angotta’s answering machine before February
11, 2000, in which petitioner stated that he was ready to
personally meet with Revenue Officer Angotta to hand in his
appeal.
In a letter dated June 22, 2000, Appeals Officer William A.
Hirsch (Appeals Officer Hirsch) informed petitioner that
respondent’s NFTL had been assigned to him for consideration.
After repeated failed attempts by Appeals Officer Hirsch and
petitioner to get in touch with each other, Appeals Officer
Hirsch, in a letter dated July 26, 2000, informed petitioner that
6The Feb. 14, 2000, letter was not part of the record.
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