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determination, respondent’s Appeals Office stated, inter alia,
that (1) the parties had been unable to settle the instant case;
(2) that petitioner was precluded from challenging the underlying
liability for his 1995 tax year because he had the opportunity to
dispute the liability during the 1997 bankruptcy proceeding; (3)
that Barbara Drake is not a party to the instant case because she
was not a party to the petition filed with the Tax Court pursuant
to section 6330(d) and Rule 331(a); (4) that the jeopardy levy
was appropriate because petitioner appeared to be designing to
quickly place his property beyond the reach of the Government and
because petitioner’s financial solvency appears to be imperiled;
and (5) that petitioner’s offer-in-compromise is rejected on the
ground that petitioner failed to submit requested financial
verification documents necessary to evaluate the offer. On April
13, 2006, petitioner filed a response to the supplemental notice
of determination.
OPINION
I. Sections 6330 and 6331
If any person liable to pay any tax neglects or refuses to
pay such tax within 10 days after notice and demand for payment,
section 6331(a) authorizes the Secretary to collect such tax by
levy upon property belonging to the person. Notwithstanding
section 6331(a), section 6330(a) provides that no levy may be
made unless the Secretary first notifies the person in writing of
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