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On March 31, 1999, respondent mailed to petitioner a final
notice of intent to levy. See sec. 6331. The notice stated that
petitioner owed taxes, penalties, and interest totaling
$329,918.45 and $147,568.72 for the taxable years 1987 and 1988,
respectively, and that respondent was preparing to collect these
amounts by levy. The notice further stated that petitioner would
be given 30 days to request a hearing with respondent's Appeals
Office.
Petitioner timely filed a request for a hearing with
respondent's Appeals Office. On August 2, 1999, respondent's
Appeals Office issued to petitioner a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(the determination letter). The determination letter stated that
because petitioner had been issued a notice of deficiency for
1987 and 1988 and had contested the notice in the Tax Court,
petitioner was not permitted to contest his liability for the
underlying taxes in the Appeals hearing. The determination
letter further stated that respondent would proceed with the
proposed collection action.
On August 6, 1999, petitioner filed with the Court an
imperfect petition for review of the determination letter,
followed by an amended petition on September 20, 1999.
Petitioner contends that the Appeals Office erred in failing to
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Last modified: May 25, 2011