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February 21, 2006, petitioner submitted a Form 12153, Request for
a Collection Due Process Hearing, raising frivolous and meritless
arguments.
By letter dated May 18, 2006, respondent’s Appeals
settlement officer advised petitioner that a telephonic hearing
was scheduled for June 8, 2006. The letter advised petitioner
that he would be allowed a face-to-face hearing on any relevant,
nonfrivolous issue, if petitioner responded within 14 days
describing such an issue. The letter also advised that if
petitioner desired to pursue collection alternatives, he should
provide specified materials, including petitioner’s unfiled
income tax returns for 1997, 2004, and 2005.
By facsimile transmission on June 8, 2006, petitioner
declined the telephonic hearing, demanding a face-to-face hearing
but providing no information about relevant issues.
By notice of determination dated June 15, 2006, respondent’s
Appeals Office sustained the proposed levy. As part of this
determination, the Appeals settlement officer reviewed a TXMODA
computer transcript to verify that the assessments for
petitioner’s 2003 taxes were properly accomplished and that
notice and demand for payment had been issued to petitioner on
the date of assessment.
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Last modified: November 10, 2007