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petitioner submit completed Forms 433-A, Collection Information
Statement for Wage Earners and Self-Employed Individuals, and
433-B, Collection Information Statement for Businesses, as well
as completed Federal income tax returns for 1996 through 2000, by
August 3, 2001. When petitioner had not responded by September
13, 2001, AO Ford sent him a letter on that date scheduling a
conference for October 9, 2001, to which petitioner was requested
to bring the foregoing materials.
Petitioner did not appear at the scheduled conference or
otherwise respond. On February 5, 2002, Appeals issued a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination) to petitioner, in
which it was determined that the levy should proceed because
petitioner had failed to attend the scheduled conference or
otherwise respond to contacts by the Appeals officer. The notice
of determination further observed that the 1990, 1991, 1992, and
1993 liabilities were based on returns filed for those years, and
the 1996 liability was based on information respondent had on
file.
Petitioner timely petitioned this Court for review, alleging
the following errors: (i) The notice of determination did not
state that AO Ford had no prior involvement with respect to the
tax periods at issue; (ii) the notice of determination did not
contain a verification that the requirements of applicable laws
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