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The liabilities were assessed; notice and demand made;
liability remains unpaid; the Notice of Intent to Levy
was issued.
* * * * * * *
This Settlement Officer has had no previous non-CDP
contact with the taxpayer periods being considered and
is not aware of any previous compliance contact.
The compliance function followed all legal and proce-
dural requirements and the actions taken or proposed
were appropriate under the circumstances.
2. Issues raised by the taxpayer;
The issue the taxpayer raised in writing stated in
part: “The amount of tax is totally exaggerated. I’ll
explain other reasons later.”
Appeals issued an appointment letter on April 24, 2006
offering a face to face conference and scheduling a
phone conference at 10:00a.m.on June 13, 2006 if a face
to face was not preferred. The letter also requested
Form 433A Collection Information Statement for Wage
Earners and Self Employed, Forms 1040 returns for years
1999, 2000, 2001, 2002, 2003, 2004, and 2005, and proof
of sufficient income tax withholdings or estimated tax
payments for current tax year ending 2006. The infor-
mation was to be provided within 14 days from the date
of the letter.
The letter also advised the taxpayer that the issue of
the liability maybe precluded under IRC 6330(c)(2)(B)
due to the Services records showing a Notice of Defi-
ciency having been issued, and should have been re-
ceived. This notice would have provided a prior oppor-
tunity for consideration of the liability. The tax-
payer was provided with publication 3598 which provides
instructions for audit reconsideration. During the
conference the taxpayer could not remember if he had
received the Notice of Deficiency or not. He advised
that he resided at 8501 Millicent Way, Apt 2641,
Shreveport, LA from 1999 to 2005, which is during the
time the Notice of Deficiency was issued.
The taxpayer called as scheduled for the conference.
He wanted to know what he could do to settle the ac-
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Last modified: November 10, 2007