United States Tax Court October 13, 2000, No. 16718-99L (Katz v. Commissioner)

OPINION

VASQUEZ, Judge:

Petitioner filed a petition in response to respondent’s notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination).1 In his petition, petitioner alleges that the Internal Revenue Service Office of Appeals (Appeals Office) failed to hold a meaningful hearing as required by section 6320(b) (Appeals hearing).