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use in making the return required under Section 6012 of
the Code.
During the hearing, this was explained to Mr. Dunbar
and he was provided with a summary of Code sections and
applicable regulations dealing with imposition of tax
and the requirement for filing income tax returns.
Collection issued its Final Notice of Intent to Levy
and filed its NFTL based on valid and outstanding tax
liability and Mr. Dunbar was provided with the right to
request a hearing.
Collection Due Process Hearing:
This Appeals Officer has never dealt with Mr. Dunbar
before on any matter.
1. APPLICABLE LAW AND ADMINISTRATIVE PROCEDURES
We have closely reviewed the administrative file and
the other appropriate records of the Internal Revenue
Service (Audit files, transcripts, assessments made and
payments credited and actions by the Collection Divi-
sion). We have made inquires to the Secretary regard-
ing the issues raised during the hearing and the Secre-
tary furnished us with their position on these matters.
The tax liability is valid. A Final Notice of Intent
to levy was issued based on an outstanding liability
and Mr. Dunbar was provided with the right to request a
hearing. His request was timely and a hearing was held
on July 9, 2001.
The Final Notice issued is based on a valid and out-
standing tax liability for 1992, 1993 and 1994 * * *.
Mr. Dunbar was provided with his right to request a
hearing. A Collection Due Process Hearing was held at
the Dallas Appeals Office.
Our determination is that the Secretary has complied
with the applicable law and administrative procedures
with respect to the periods included in the Secretary’s
notice.
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Last modified: May 25, 2011