Michael E. Vierow - Page 4

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          hearing or to continue his hearing by correspondence.  Petitioner           
          chose to have his hearing conducted via correspondence.                     
               As part of the hearing, Appeals Officer Chambers reviewed              
          the administrative file, which included the notices of deficiency           
          and Forms 4340, Certificate of Assessments, Payments, and Other             
          Specified Matters.  Appeals Officer Chambers also reviewed a                
          certified mail list, which was not part of the administrative               
          file, to determine whether respondent mailed the notices of                 
          deficiency via certified mail to petitioner at his correct                  
          address.                                                                    
               On July 28, 2003, petitioner sent Appeals Officer Chambers a           
          letter in which he argued that in order to meet the verification            
          requirement of section 6330(c)(1) respondent needed to establish            
          that respondent properly (1) issued statutory notices of                    
          deficiency for the years in issue, (2) made the assessments for             
          the years in issue, (3) issued notices and demand for payment,              
          (4) issued notice of intent to levy, and (5) issued notice of               
          petitioner’s right to a hearing.  Petitioner also claimed he had            
          not received any “assessment notices” from respondent for the               
          years in issue.                                                             
               On October 8, 2003, respondent sent petitioner a Notice of             
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 (notice of determination) for the years in issue.               
          Appeals Officer Chambers determined that the requirements of                






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