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the proposed levy regarding income taxes for 1999 and 2000.
During August 2004, petitioner and respondent conducted by
correspondence an equivalent hearing regarding the proposed levy
regarding income taxes for 2001.
On August 26, 2004, respondent sent petitioner: (1) A
decision letter concerning equivalent hearing under section 6320
and/or 6330 stating that the notice of intent to levy for income
taxes for 2001 would not be withdrawn; (2) a notice of
determination concerning collection action(s) under section 6320
and/or 6330 stating that the notice of intent to levy for income
taxes for 1999 and 2000 would not be withdrawn; (3) a notice of
determination concerning collection action(s) under section 6320
and/or 6330 stating that the notice of Federal tax lien for
income taxes for 1999, 2000, and 2001 would not be withdrawn; and
(4) a notice of determination concerning collection action(s)
under section 6320 and/or 6330 stating that the notice of Federal
tax lien regarding the section 6702 penalty for 1999 and 2000
would not be withdrawn.
On September 9, 2004, petitioner submitted a document,
postmarked September 3, 2004, that the Court filed as a petition
for lien or levy action under section 6320(c) or 6330(d)
(petition). Petitioner titled the petition “FIRST AMENDMENT
VERIFIED APPEAL OF ADMINISTRATIVE ACTIONS AND DETERMINATIONS
JURISDICTIONAL CHALLENGE MOTION FOR FINDINGS OF FACTS AND
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