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Linda, requesting a section 6330 hearing. In that form,
petitioner contended, among other things, that the applicable
statute of limitations barred collection of his tax liability for
taxable year 1989 and that he previously had paid his tax
liabilities for taxable years 1990, 1991, 1992, 1993, 1996, and
1997.
By letter dated February 29, 2000, respondent sent
petitioner copies of respondent’s transcripts of petitioner’s
accounts for the subject taxable years. The letter stated that
if petitioner felt that he was not properly credited for any
payment, he should provide respondent supporting documentation.
Petitioner did not provide respondent any documentation to
support the allegations contained in his Form 12153.
On April 7, 2000, respondent sent petitioner a letter
informing him that the requested section 6330 hearing would be
scheduled for May 4, 2000, at 2:30 p.m. The letter stated that
if petitioner did “not appear for the hearing or call to
reschedule, * * * [his] case will be closed in Appeals and a
Determination Letter will be issued.” Petitioner failed to
attend the scheduled section 6330 hearing and did not call to
reschedule it.
On May 22, 2000, respondent sent petitioner a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination). The notice of
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