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were invalid and that proper assessments were not entered for
several of the years in issue. During the trial, and over
petitioner’s objection, the Court allowed respondent to offer
into evidence Forms 4340, Certificate of Assessments, Payments
and Other Specified Matters, regarding petitioner’s account for
the years 1993 to 1997. Following the trial, on March 11, 2005,
respondent’s Motion to Permit Levy was filed with the Court.
OPINION
I. Collection Actions
A. Lien and Levy
Sections 6320 (pertaining to Federal tax liens) and 6330
(pertaining to levies) establish procedures for administrative
and judicial review of certain collection actions. As an initial
matter, the Commissioner is required to provide a taxpayer with
written notice that a Federal tax lien has been filed and/or that
the Commissioner intends to levy; the Commissioner is also
required to explain to the taxpayer that such collection actions
may be challenged on various grounds at an administrative
hearing. See Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza
v. Commissioner, 114 T.C. 176, 179 (2000).
Section 6330(c)(1) imposes on the Appeals Office an
obligation to obtain verification that “the requirements of any
applicable law or administrative procedure have been met.”
Section 6330(c)(2) prescribes the matters that a person may raise
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