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4. The requirements of applicable law or administrative
procedures have been met, and the actions taken were appropriate
under the circumstances.
5. Petitioner did not identify any relevant, nonfrivolous
issue.
6. The proposed levy balances the need for efficient
collection with petitioner’s concern that any collection action
be no more intrusive than necessary.
By undated letter received by the Court November 13, 2006,
petitioner indicated that he wished to appeal the notice of
determination. The Court filed the letter as petitioner’s
imperfect petition and ordered him to file a proper amended
petition. On March 15, 2007, the Court received and filed
petitioner’s amended petition. In his amended petition,
petitioner alleged as follows:
During the Collection Due Process Hearing, it is
believed that the Respondent DID NOT satisfy ALL of the
appropriate requirements. The Petitioner was NOT
allowed to challenge the liability of the assessed tax,
therefore petitioner was NOT given a fair and impartial
hearing. Petitioner requested pertinent documents and
files, but respondent REFUSED to comply. Petitioner
also requested to be provided with acceptable evidence
that would further support the Respondents’ claim of
this assessed tax. Petitioner was not allowed to
dispute any discrepancies found within Respondents’
claim of tax liability. Petitioner was NOT properly
informed of his rights. Petitioner was not given due
process.
On August 23, 2007, the Court issued petitioner a notice
setting his case for trial during its January 28, 2008, San
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