Robert B. Keenan - Page 10

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               Petitioner argues that respondent failed to comply with the            
          notice requirements of sections 6303, 6330, and 6331.  Mr.                  
          Climan, however, verified that the proper assessments were made             
          and the requisite notices had been sent to petitioner in                    
          accordance with section 6303.6  Moreover, the record clearly                
          establishes that respondent provided petitioner with notice of              
          his intent to levy and of petitioner’s right to a hearing as                
          required by sections 6331 and 6330, respectively.                           
               Petitioner also asserts that respondent erred by changing              
          settlement officers.  We find this argument completely without              
          merit, as the reassignment of petitioner’s case to Mr. Sample was           
          done to accommodate petitioner’s own request to conduct the                 
          hearing at the Appeals Office located in Thousand Oaks.                     
          Petitioner failed to allege facts or demonstrate a connection as            
          to how this reassignment impacts the validity of his section 6330           
          proceeding.                                                                 
               Finally, petitioner claims that respondent violated                    
          petitioner’s right to procedural due process by refusing to allow           
          him to make an administrative record of all of his issues.                  
          Petitioner argues that Mr. Sample’s decision to adjourn the                 
          Appeals hearing deprived him of a full and complete hearing.  A             


               6 Mr. Climan confirmed that the Internal Revenue Service               
          (IRS) issued notice and demand to petitioner for the years at               
          issue by examining transcripts of account using the IRS’s                   
          integrated data retrieval system.                                           




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