-7-
2005, petitioner requested of respondent in writing a hearing
with regard thereto.
A telephone hearing with an Appeals officer located in
Birmingham, Alabama, was scheduled for April 20, 2005, but was
later rescheduled for May 17, 2005. On May 4, 2005, petitioner
requested that the hearing be rescheduled and be relocated to
respondent’s Riverside, California, office, near petitioner’s
attorney’s law office. This request was denied by respondent.
Petitioner did not participate in the May 17, 2005,
telephone hearing, but petitioner did submit to respondent’s
Appeals Office written correspondence in which petitioner made a
number of arguments relating to the amount of petitioner’s
underlying Federal income taxes.
In connection with the hearing, respondent’s Appeals officer
reviewed a transcript of account Form 4340, Certificate of
Assessments, Payments, and Other Specified Matters, relating to
petitioner’s Federal income taxes for the years in issue,
verified that respondent’s assessments were made against
petitioner for the years 1995, 1996, and 1997, and concluded that
respondent’s proposed levy action was appropriate and not
unnecessarily intrusive.
On May 25, 2005, respondent’s Appeals Office issued to
petitioner a notice of determination under section 6330
sustaining respondent’s proposed levy action.
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