Lionel Brown - Page 6

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               Respondent issued to petitioner a notice of determination              
          that sustained the proposed use of a levy to collect petitioner’s           
          unpaid Federal income tax liabilities for taxable years 1997 and            
          2000.  In the notice of determination, respondent concluded that            
          petitioner had not verified that he qualifies for currently not             
          collectible status or any other type of collection alternative.             
          2.   The Petition and Motion                                                
               Petitioner submitted to this Court a timely petition                   
          appealing respondent’s determination.  Therein, petitioner                  
          specified that he does not challenge the amount of the underlying           
          tax liabilities.  He challenges the “appropriateness of                     
          collection actions based on circumstances, etc” and the “offers             
          of collection alternatives as listed without reference to the law           
          as written and efforts to settle by citizen (L Brown)(sic).”                
               Respondent moved for summary judgment.  The Court ordered              
          respondent’s motion set for hearing at the call of the calendar             
          in Los Angeles.  After the hearing, the Court denied respondent’s           
          motion for summary judgment.                                                
                                     Discussion                                       
               Section 6330(a) provides that no levy may be made on any               
          property or right to property of any person unless the Secretary            
          has notified such person in writing of the right to a hearing               
          before the levy is made.  If the person makes a request for a               







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