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$11,776, which, according to petitioner, resulted in his being
falsely accused by respondent of writing a bad check for $10,000.
On November 26, 2001, a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330 was sent to
petitioner. In the notice, the Appeals officer determined that
all applicable laws and administrative procedures had been
satisfied. With respect to petitioner's expressed concerns about
his 1995 taxes, the Appeals officer explained that a remittance
submitted by petitioner in 1997 and intended by him to be applied
to that year's taxes was instead applied to 1995 taxes because
the return and payment for 1995 had been received late,
triggering an assessment of additions to tax and interest for
that year to which the 1997 payment had been applied. With
respect to 1997, the Appeals officer determined that, because
respondent's incorrect posting of petitioner's $1,776 check as
$11,776 had resulted in an erroneous refund with respect to 1997,
the assessed failure to pay addition to tax would be abated. As
for the remaining liabilities that were the subject of the levy,
the Appeals officer determined: "The tax owed is from the
original return for 1997, 1998 and 1999. Therefore, I recommend
the government sustain the tax liability for * * * [those tax
periods]." Concluding that the proposed levy represented an
appropriate balancing of the need for efficient collection with
the concern that the collection action be no more intrusive than
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