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to forgo recording the conference. The notice of determination:
(i) Stated that Appeals had verified that all of the requirements
of applicable law and administrative procedures had been met,
including the making of a valid assessment; (ii) answered
petitioner's contention that he never received notice and demand
for payment by noting that the settlement officer had provided
petitioner a copy of his Form 4340 for 2000 documenting that
notice and demand for payment had been sent; (iii) answered
petitioner's challenge to the existence of the underlying tax
liability by advising that petitioner was precluded from pursuing
such a challenge because he had received a notice of deficiency
(as indicated by his correspondence referencing it); (iv) noted
that petitioner had failed to provide the requested financial
information regarding potential collection alternatives; and (v)
concluded that the proposed levy balanced the need for the
efficient collection of taxes with the legitimate concern that
the collection action be no more intrusive than necessary.
Petitioner timely filed a petition in response to the notice
of determination, wherein he alleged, inter alia, that he had
never received a notice of deficiency, that he had not received
any "taxable" income for 2000, and that respondent had violated
the law by denying petitioner his right to record his section
6330 conference pursuant to section 7521.
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Last modified: May 25, 2011