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On December 18, 2004, respondent issued petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing
(notice of intent to levy). On January 13, 2005, respondent
issued petitioner a Notice of Federal Tax Lien Filing and Your
Right to a Hearing Under I.R.C. § 6320 (notice of Federal tax
lien). On January 18 and February 23, 2005, respectively,
respondent received two Forms 12153, Request for a Collection Due
Process Hearing, in response to the notice of intent to levy and
the notice of Federal tax lien. In the Forms 12153, petitioner
argued that respondent violated petitioner’s due process rights
by not allowing him “to confront and cross-examine the witnesses”
who provided respondent with petitioner’s bank records and by not
requesting technical advice from respondent’s National Office.
On March 4, 2005, Appeals Officer Catherine Smith (Ms.
Smith) was assigned to petitioner’s case. On April 13, 2005, Ms.
Smith sent petitioner a letter stating that courts have
considered petitioner’s arguments to be frivolous or groundless.
Ms. Smith explained what issues could be addressed during the
section 6330 hearing, requested that petitioner submit financial
information and any desired collection alternatives, and
scheduled a telephonic section 6330 hearing for May 11, 2005.
Petitioner’s section 6330 hearing was held on May 11, 2005,
during which petitioner made the same arguments raised in the
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Last modified: November 10, 2007