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Petitioner’s hearing was conducted through face-to-face meetings
and written and oral communication. The IRS sent a notice of
determination to petitioner on June 21, 2005, sustaining the
IRS’s proposed levy with respect to petitioner’s outstanding
balances. The notice of determination stated:
[W]e believe that the requirements of law and
administrative procedure have been met * * * .
Assessments appear correct and [sic] based on
established law, policy, and procedure. Notices of
assessment or proposed deficiency assessments were sent
to the address of record as required by statute. * * *
* * * * * * *
* * * You have had previous opportunities to contest
the income tax liabilities for 1982, 1983, and 1984
(which are the result of a Tax Court decision involving
a partnership in which you had invested) and cannot
raise that issue in the Due Process venue. * * *
* * * * * * *
The levy is intrusive but it is appropriate in this
instance. You have made only occasional payments
against these liabilities and there is no indication
that the liabilities will be paid voluntarily. You
have not proposed a specific alternative to collection.
OPINION
The Internal Revenue Service Restructuring and Reform Act of
1998, Pub. L. 105-206, sec. 3401, 112 Stat. 685, 746, granted the
Court jurisdiction to review the Commissioner’s determination as
to the propriety of a filing of a notice of Federal tax lien
under section 6320 or a proposed levy upon property under section
6330. Section 6330 generally provides that the IRS cannot
proceed with the collection of taxes by way of a levy on a
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