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TAX RETURNS. THEREFORE, A LIEN AND LEVY WILL INHIBIT
THE TAXPAYER TO OBTAIN PROPER FINANCING. [Reproduced
literally.]
On January 19, 2006, a settlement officer with the Appeals
Office (settlement officer) sent a letter to petitioner with
respect to petitioner’s Form 12153. In that letter, the settle-
ment officer offered petitioner the opportunity to have a hearing
on February 28, 2006. On February 28, 2006, petitioner’s autho-
rized representative called the settlement officer and requested
a two-week period within which to (1) submit a tax return for
each of petitioner’s taxable years 2000, 2001, and 2002 and
(2) propose a collection alternative. The settlement officer
granted that request. On March 28, 2006, the settlement officer
called petitioner’s authorized representative (March 28, 2006
call). During the March 28, 2006 call, petitioner’s authorized
representative indicated that he had nothing to submit with
respect to petitioner’s taxable years 2000, 2001, and 2002 and
requested that a notice of determination be issued with respect
to those years.
On April 5, 2006, the Appeals Office issued to petitioner a
notice of determination with respect to petitioner’s taxable
years 2000, 2001, and 2002. That notice stated in pertinent
part:
Summary of Determination
You did not offer any collection alternatives for
Appeals consideration. Collection is sustained.
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