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An attachment to the notice of determination stated in pertinent
part:
DISCUSSION AND ANALYSIS
WERE THE REQUIREMENTS OF ANY APPLICABLE LAW OR PROCE-
DURE MET?
Based upon the best information available, the Service
complied with the applicable laws and procedures in
pursuing collection of the tax liabilities.
• The assessments were made per IRC �� 6201, 6203,
6211, 6212, and 6213.
• The notice and demand for payment letter was
mailed to the last known address, within 60 days
of the assessment, as required by IRC � 6303.
• IRC � 6321 provides a statutory lien when a tax-
payer neglects or refuses to pay a tax liability
after notice and demand. To be valid against
third parties, except for other government enti-
ties, a notice of lien must be filed in the proper
place for filing per IRC �� 6323(a) and (f).
• IRC � 6320 requires the IRS to give notice to a
taxpayer in writing no later than five working
days after filing a notice of lien of the tax-
payer’s right to request a hearing. This notice
was mailed to you.
• IRC [�] 6330 requires the IRS to give notice to a
taxpayer in writing at least thirty days prior to
levy action of the taxpayer’s right to request a
hearing.
• There was a balance due when the CDP notice was
issued per IRC � 6322. The CDP notice was sent by
certified mail return receipt requested to your
last known address.
• The collection statute has been suspended as the
result of your CDP request.
The above information was verified through a review of
computer transcripts and information contained in the
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Last modified: May 25, 2011