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Appeals officer a written statement of petitioner’s position
before the scheduled conference. On July 24, 2002, respondent’s
Appeals officer and petitioner’s representative met for the
conference.
On September 16, 2004, respondent sent petitioner a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. The notice of determination stated that
respondent had determined that the notice of deficiency regarding
petitioner’s 1996 gift tax return was valid. Since the validity
of the notice of deficiency was the only issue raised at his
hearing and petitioner did not suggest any collection
alternatives, respondent determined that the lien and levy
actions “[balanced] the need for the efficient collection action
to be no more intrusive than necessary.”
On October 15, 2004, petitioner timely filed a petition
appealing respondent’s determination. In his petition, the only
issue petitioner raised with respect to the notice of
determination was that respondent’s Appeals officer erred in
determining that the notice of deficiency was valid for 1996.
Petitioner’s claim is essentially that the proposed
collection action was based on an invalid assessment because
petitioner was not afforded the requisite notice of deficiency.
In petitioner’s view, the notice of deficiency he received on
March 22, 2000, was invalid because it referenced tax year 1995
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