- 8 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007