Ralph Tashjian - Page 9

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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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