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tax lien) with respect to taxable years 1997 and 1998.
In early June 2001, in response to the notice of intent to
levy and the notice of tax lien, petitioner, through her autho-
rized representative, mailed to respondent Form 12153, Request
for a Collection Due Process Hearing (Form 12153), and requested
a hearing with respondent’s Appeals Office (Appeals Office). In
her Form 12153, petitioner raised various challenges to respon-
dent’s collection activity that respondent determined to be
frivolous.
A settlement officer with respondent’s Appeals Office
(settlement officer) scheduled several hearings (Appeals Office
hearings) with petitioner and her authorized representative with
respect to the notice of intent to levy and the notice of tax
lien. Petitioner and her authorized representative refused to
attend any of the Appeals Office hearings that the settlement
officer had scheduled. That was because the settlement officer
refused to allow petitioner and her authorized representative to
audio record any such hearing.
On February 14, 2003, the Appeals Office issued to peti-
tioner a notice of determination concerning collection action(s)
under section 6320 and/or 6330 (notice of determination). That
notice stated in pertinent part:
It has been determined that the lien filing and pro-
posed levy action are sustained. The Internal Revenue
Service has complied with code and procedural require-
ments in collecting the tax.
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Last modified: May 25, 2011