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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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Last modified: May 25, 2011