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evidence to challenge and disprove the liability the IRS claims I
owe.”
Petitioner did not submit any of the requested information
to the settlement officer. On October 12, 2006, the Appeals
Office issued a notice of determination that the proposed levy
action was appropriate and could proceed. Attached to the notice
was a document summarizing the issues, the background, and the
discussion and analysis supporting the determination. The
following information was included in the attachment.
1. The Service mailed a notice of deficiency to petitioner
for 2002, and he petitioned the Tax Court. Because he had a
prior opportunity to appeal the underlying liability for 2002, he
could not raise any issue regarding the underlying liability at
the collection due process hearing.
2. Petitioner was offered a face-to-face hearing if he
identified any relevant, nonfrivolous issues in writing or by
calling as requested, but he did not do so.
3. Petitioner was offered the opportunity to discuss
collection alternatives to the proposed levy action if he
provided the requested financial information, but petitioner
failed to submit the information. In addition, petitioner was
not in compliance with his filing and payment obligations.
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Last modified: March 27, 2008