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informed petitioner that if he did not participate, a
determination would be made on the basis of the administrative
record. Petitioner did not participate in the telephone
conference and made no attempt to reschedule.
On October 20, 2004, respondent sent petitioner a letter
advising him that a determination would be made by November 12,
2004. Respondent requested that petitioner submit any additional
documentation that he wished considered in making the
determination.
Petitioner sent respondent a letter on October 27, 2004,
again requesting a face-to-face hearing. Petitioner stated that
a telephone conference was unacceptable because “Documents cannot
be produced over the telephone, nor can an accurate record of
such a meeting.” Petitioner did not raise any additional
arguments in the letter.
Petitioner did not provide respondent with any additional
documentation to consider before making the determination.
On December 28, 2004, respondent sent petitioner a Notice of
Determination Concerning Collection Actions Under Section 6320
and/or 6330 with respect to the years in issue. In the notice of
determination, respondent states:
A review of the administrative file indicates that
statutory and administrative requirements that needed
to be met with respect to the filing of the Notice of
Federal Tax Lien were in fact met in this case.
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