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in the form of a face-to-face meeting with the Appeals
officer on a specific date. Petitioner failed to appear
for the hearing on the date specified, and he did not
contact the Appeals officer to schedule a hearing on
another date.
Several days later, the Appeals officer issued the
subject notice of determination. The following summary of
the Appeals officer’s determination is set forth therein:
We have determined that the Notice of Intent
to Levy issued on the periods listed above
[viz 1991, 1996, 1998, and 1999] is valid and
appropriate. All legal and procedural require-
ments were met in its issuance. No collection
alternatives were proposed, so levy is the only
means to collect the liability at this time.
The last sentence of the above summary appears to be
contradicted by an attachment to the determination letter
which contains a section entitled “Relevant issues raised
by the taxpayer”. In that section, the Appeals officer
states: “The taxpayer claimed [that] an installment
agreement would be proposed * * * [and] also claimed that a
wage levy would keep him from getting a job.” Apparently,
the Appeals officer derived those claims from the letter
submitted with petitioner’s request for CDP hearing, quoted
above. The Appeals officer states in the attachment that
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Last modified: May 25, 2011