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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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