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8. You have made no other payments.
9. At your request, the audit was reconsidered,
but the adjustments were not changed.
DISCUSSION AND ANALYSIS
Applicable Law and Administrative Procedures
With the best information available, the requirements
of various applicable law or administrative procedures
have been met.
IRC �6331(d) requires that the Service notify a tax-
payer at least 30 days before a Notice of Levy can be
issued. IRC �6330(a) provides that no levy may be made
unless the Service notifies a taxpayer of the opportu-
nity for a hearing with Appeals.
A Letter 1058 Final Notice--Final Notice of Intent to
Levy and Your Right to a Hearing was sent to you by
certified mail 4/8/2004.
A levy source was identified prior to issuance of the
Notice of Intent to Levy.
IRC �6330(c)(2)(A) allows the taxpayer to raise any
relevant issue relating to the unpaid tax or the pro-
posed levy at the hearing.
You were provided the opportunity to raise any issue at
the hearing.
IRC �6330(c)(2)(B) provides that a taxpayer may only
raise challenges to the existence or amount of the
underlying tax liability if the person did not receive
a statutory notice of deficiency for such tax liablity
or did not otherwise have an opportunity to dispute the
liability.
The Appeals Officer has had no prior involvement with
respect to these liabilities as required by IRC
�6330(b)(3).
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Last modified: May 25, 2011