Merry J. Chandler - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  This case is before the Court to review a             
          determination (the determination) made by respondent’s Appeals              
          Office (Appeals) that respondent may proceed to collect by levy             
          petitioner’s tax liabilities for her 1988, 1993, 1994, 1996,                
          1997, and 1998 taxable (calendar) years.  We review the                     
          determination pursuant to section 6330(d)(1).1  At the start of             
          the trial in this case, respondent conceded that petitioner had             
          paid in full her liability for 1993 and that respondent would not           
          pursue a levy with respect to that year.  We accept that                    
          concession and will reflect it in our decision.  We therefore               
          consider only respondent’s proposed levy with respect to                    
          petitioner’s unpaid liabilities for 1988, 1994, 1996, 1997, and             
          1998 (collectively, the unpaid liabilities).  Petitioner’s sole             
          argument on brief is that Appeals erred in making the                       
          determination because it failed to accord petitioner the face-to-           
          face interview that she claims to have requested.  Because                  
          petitioner has failed to persuade us that she requested a face-             
          to-face interview, we sustain the determination.2                           

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code of 1986.                                          
               2  During the trial in this case, petitioner also claimed              
          that she had paid in full her liability for 1997 and that Appeals           
          Officer McNichol (the individual in Appeals assigned to her case)           
          had failed to allow her reasonable time to submit an amended                
          offer in compromise.  Respondent denied both of those claims.  At           

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