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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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