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Petitioner did not respond to the June 14, 2001 letter and
did not provide the IRS Appeals Office with the information
requested in that letter.
On July 14, 2001, Mr. Armstrong, who at the time was no
longer married to petitioner,4 called the Appeals officer and
left a message on his answering machine that petitioner and he
would be filing an amended tax return for each of their taxable
years 1992 and 1995. Mr. Armstrong did not indicate that peti-
tioner wanted to schedule a face-to-face hearing with the Appeals
officer. In fact, Mr. Armstrong did not indicate that petitioner
wanted to schedule any type of hearing with the Appeals officer
and did not indicate any times when petitioner would be available
to speak to the Appeals officer.
Petitioner declined the opportunities offered to her by the
IRS Appeals Office to have a hearing with respect to respondent’s
notice of intent to levy.
On July 24, 2001, the IRS Appeals Office issued to peti-
tioner under section 63305 a notice of determination with respect
to petitioner’s taxable years 1992 and 1995. That notice stated
in pertinent part:
4The record does not disclose that Mr. Armstrong had a power
of attorney or similar document signed by petitioner authorizing
him to represent petitioner before the IRS Appeals Office.
5Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times.
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Last modified: May 25, 2011