Robert E. Crandall - Page 9

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               Petitioner subsequently filed a posttrial brief.  He therein           
          recapitulated the position taken throughout these proceedings and           
          at trial, focusing once again on lack of a recorded hearing and             
          of sufficient verification and documentation of procedural                  
          requisites.  Respondent elected not to file a brief.                        
          I.  Collection Actions                                                      
               A.  General Rules                                                      
               Section 6331(a) authorizes the Commissioner to levy upon all           
          property and rights to property of a taxpayer where there exists            
          a failure to pay any tax liability within 10 days after notice              
          and demand for payment.  Sections 6331(d) and 6330 then set forth           
          procedures generally applicable to afford protections for                   
          taxpayers in such levy situations.  Section 6331(d) establishes             
          the requirement that a person be provided with at least 30 days’            
          prior written notice of the Commissioner’s intent to levy before            
          collection may proceed.  Section 6331(d) also indicates that this           
          notification should include a statement of available                        
          administrative appeals.  Section 6330(a) expands in several                 
          respects upon the premise of section 6331(d), forbidding                    
          collection by levy until the taxpayer has received notice of the            
          opportunity for administrative review of the matter in the form             
          of a hearing before the IRS Office of Appeals.  Section 6330(b)             

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