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to $3,000. The letter provided instructions for the filing of an
appeal of the disallowance. Pursuant to the instructions,
petitioner appealed the disallowance in the Letter 105C by means
of a letter to respondent dated May 17, 2002, in which he offered
his reasons for disagreeing, including a declaration that his
statements were true under penalties of perjury (Appeals
request).
On August 10, 2002, before responding to petitioner's
Appeals request, respondent sent petitioner a "Final Notice of
Intent to Levy and Notice of Your Right to a Hearing" (Notice of
Intent to Levy), notifying petitioner that respondent intended to
satisfy petitioner's outstanding 2000 tax liability by a levy,
and advising petitioner of his right to request a hearing.
Petitioner timely requested a hearing on a Form 12153, Request
for a Collection Due Process Hearing, sent to respondent on
September 6, 2002. Petitioner's Form 12153 disputed both the
underlying tax liability and the "appropriateness of the
collection action", in light of the fact that consideration of
his Appeals request was still pending.
At some point, petitioner's Appeals request was referred to
and considered by respondent's Office of Appeals. On April 28,
2003, before any action was taken with respect to petitioner's
hearing request under section 6330, the Appeals Office issued
petitioner a written response to his Appeals request. Treating
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