Fred A. Windover - Page 9




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         exact amount shown as due on that return, as a clear designation             
         as a payment for 1999”.                                                      
              None of petitioner’s positions persuaded respondent to forgo            
         collection of petitioner’s 1999 tax liability.  As noted above,              
         in a Notice of Determination Concerning Collection Action(s)                 
         Under Section 6320 and/or 6330, dated May 23, 2005, respondent               
         determined to proceed with the collection by levy of petitioner’s            
         1999 Federal income tax liability.6                                          
                                     Discussion                                       
              The parties are not at odds regarding the technical                     
         provisions of sections 6320 and 6330.  Furthermore, petitioner               
         does not claim that respondent failed to satisfy any of the                  
         mechanical or procedural obligations contemplated by those                   
         statutes.  Consequently, we see little point in a detailed                   
         discussion regarding those requirements.  Instead, we turn our               
         attention immediately to petitioner’s complaints and begin with              
         his position regarding the timing of the filing of the NFTL.                 
              According to petitioner, the NFTL should not have been filed            
         while his request for an administrative hearing with respect to              



               6  Respondent’s correspondence to petitioner during                    
          administrative consideration references both the notice of intent           
          to levy and the NFTL.  Proceeding with one administrative hearing           
          in response to both collection devices is certainly contemplated            
          under the statutory scheme.  See sec. 6320(b)(4).  Nevertheless,            
          for reasons not explained, the notice of determination upon which           
          this case is based references only respondent’s intention to                
          levy.                                                                       





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