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verification from the Secretary that the requirements of any
applicable law or procedure had been met.
On September 12, 2003, respondent sent petitioner a letter
to request that petitioner complete a Form 433A, Collection
Information Statement for Individuals, to assist in considering
collection alternatives. Petitioner did not complete and return
the Form 433A to respondent.
On October 6, 2003, respondent sent petitioner a letter
outlining respondent’s policy at the time of not granting face-
to-face hearings to individuals raising only frivolous arguments.
A telephonic interview was offered and scheduled for November 5,
2003. On October 22, 2003, petitioner responded to the October
6, 2003, letter by stating: “to summarize your position you are
NOT going to allow me to have a hearing that I can record and you
will NOT permit me to bring up relevant issues that I covered in
my CDP request”. Petitioner refused to participate in a
telephonic interview with respondent.
On December 31, 2003, respondent issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination) with regard to
1999. The notice of determination stated:
Appeals considered whether the collection action taken
or proposed balances the need for the efficient collection
of the taxes with the legitimate concern of the taxpayer
that any collection action be no more intrusive than
necessary. We find that enforced collection action is not
more intrusive than necessary because the Automated
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Last modified: May 25, 2011