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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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Last modified: May 25, 2011