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Besides the entry on October 12, 2001, no entry in the case
activity record references any discussion of a personal
conference.
On February 19, 2002, Appeals issued to petitioner the
determination.
OPINION
I. Introduction
If any person liable for Federal tax liability neglects or
refuses to make payment within 10 days of notice and demand, the
Commissioner is authorized to collect the tax by levy on that
person’s property. See sec. 6331(a). As a general rule, at
least 30 days before taking such action, the Commissioner must
provide the person with a written final notice of intent to levy
that describes, among other things, the administrative appeals
available to the person. See sec. 6331(d).
Upon request, the person is entitled to an administrative
review hearing before Appeals (a collection due process hearing).
Sec. 6330(b)(1). Appeals must offer the person an opportunity
for a hearing, in person, at the Appeals Office closest to the
person’s residence. See sec. 301.6330-1(d)(2), Q&A-D7, Proced. &
Admin. Regs. Nevertheless, a collection due process hearing
“may, but is not required to, consist of a face-to-face meeting,
one or more written or oral communications between an Appeals
officer or employee and the taxpayer * * *, or some combination
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Last modified: May 25, 2011