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advised that no tape or stenographic recordings of the conference
would be allowed, and that petitioner would be precluded, under
section 6330(c)(2)(B), from challenging the underlying liability
for 2000 because he had received a notice of deficiency for 2000
but had not filed a petition in response thereto. The letter
included a copy of the Form 4340 for petitioner's 2000 taxable
year recording that notice and demand for payment had been made,
contrary to petitioner's earlier claim. The letter further
advised that if petitioner wished to consider alternatives to the
proposed levy action, such as an installment agreement, he should
bring with him a completed Form 433-A, Collection Information
Statement for Individuals, as well as completed income tax
returns for 2001 and 2002.
Petitioner appeared for the conference, rescheduled for
September 10, 2003, at his request, accompanied by a witness and
a court reporter. The settlement officer terminated the
conference rather than allow petitioner to record it.
On September 23, 2003, a Letter 3193, Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) was issued to petitioner.
The settlement officer determined that the proposed levy action
should be sustained in light of petitioner's refusal to abide by
the procedures the Office of Appeals had established for
conducting section 6330 conferences, notably petitioner's refusal
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