John Shere - Page 5




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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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