Kenneth A. Sapp - Page 9

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          liabilities for 1990, 1991, and 1993, acknowledged the Appeals              
          officer's willingness to let him do so but stated it would                  
          nonetheless be futile, and addressed the liabilities only by                
          contending that he owed "but a small fraction" of the amounts               
          sought to be collected; (iv) contended that he had not filed a              
          return for 1992 and consequently was entitled to receive a notice           
          of deficiency before the underlying liability for that year could           
          be assessed or collected; (v) raised questions concerning                   
          collection alternatives; (vi) contended that the notice of                  
          determination was invalid and the 2003 supplemental notice was              
          improper; (vii) contended that improper ex parte contacts                   
          occurred between respondent's Office of Chief Counsel and Appeals           
          after his case was remanded by this Court for a hearing; and                
          (viii) contended that Appeals failed to take steps to have                  
          references to petitioner as a "tax protester" expunged from                 
          respondent's files.                                                         
               On March 3, 2004, Settlement Officer Waters issued a                   
          supplemental notice of determination (2004 supplemental                     
          determination) that (i) contained a verification that all                   
          applicable laws and administrative procedures had been met, (ii)            
          considered the issues raised by petitioner, (iii) found that a              
          balancing of the need for efficient tax collection with                     
          legitimate concerns that the collection action be no more                   
          intrusive than necessary indicated the proposed levy was                    






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