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Ms. Dellosso had no prior involvement with you concern-
ing the applicable tax periods before this CDP case.
The CDP notice was sent by certified mail return re-
ceipt requested to your last known address.
Ms. Dellosso verified all laws and administrative
procedures were met through review of computer tran-
scripts and actions documented in the administrative
file.
Verification of “Validity of Assessment”
The assessment for your U.S. Individual Income Tax
return for the tax periods ended 12/31/95 and
12/31/1998 are valid. This assessments were made after
you failed to file a valid petition with the US Tax
Court. The deficiency notice was issued on June 10,
2002. Your subsequent attempt to petition the court is
sufficient proof that you received the Statutory
Notice.
2. Issues and/or Collection Alternatives Raised by the
Taxpayer
You raised the issue of the underlying tax liability,
which is precluded from this hearing. You did not
raise any additional issues or collection alternatives.
Collection Action Be No More Intrusive Than Necessary
IRC § 6330 requires that the Appeals Office consider
whether a proposed collection action balances the need
for efficient collection of taxes with the legitimate
concern that any collection action be no more intrusive
than necessary.
You did not offer a collection alternative that Appeals
could accept as an alternative to the Notice of Levy
that was issued to your employer. Therefore, our
determination is that the levy is sustained. This
balances the government’s need for the efficient col-
lection of tax with your concern that collection be no
more intrusive than necessary. [Reproduced literally.]
In the petition commencing the instant case, petitioner
alleged that he believes that he owes only “$1383 (plus penalties
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Last modified: November 10, 2007