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years on February 21, 2000. Notices of balance due were sent to
petitioner on that date, as well as on March 27 and May 1, 2000.
Thereafter, on October 3, 2002, respondent issued to
petitioner a Final Notice of Intent to Levy and Notice of Your
Right to a Hearing, with regard to the 1993 through 1996 years.
Respondent on November 7, 2002, received from petitioner a Form
12153, Request for a Collection Due Process Hearing, setting
forth her disagreement with the proposed collection action, as
follows:
(1) There was a failure to determine a deficiency; (2)
There was a failure to issue a Notice of Deficiency;
(3) There was a failure to generate an assessment list;
(4) There was a failure of the Commissioner to certify
and transmit the assessment list; (5) There was a
failure to record the assessment; (6) failure to
provide record of assessment; and, (7) failure to send
Notice of Assessment.
On December 3, 2002, respondent sent to petitioner a letter
acknowledging receipt of her Form 12153. Petitioner responded by
submitting to respondent a document entitled “Declaration of
Thomasita Taylor” stating, inter alia, that she “did not receive
the Notices of Assessment” with respect to the 1993 through 1996
years. By a letter dated May 15, 2003, the settlement officer to
whom petitioner’s case had been assigned scheduled a hearing for
June 11, 2003, in Phoenix, Arizona. Petitioner responded with a
letter dated June 9, 2003, asking that the hearing be
rescheduled. A June 11, 2003, letter from the settlement officer
rescheduled the hearing for July 24, 2003, and enclosed copies of
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