- 4 - through 1988.2 Respondent concedes that the notice required by section 6320(a) was not mailed to petitioner at his last known address and that such notice was therefore invalid. See sec. 6320(a)(2)(C). In any event, petitioner did not request an administrative hearing with the Internal Revenue Service Office of Appeals (Appeals Office) in respect of the notice required by section 6320(a), nor did the Appeals Office either conduct an administrative hearing or issue a determination letter regarding the notice required by section 6320(a). On or about October 25, 1999, respondent mailed to petitioner a Final Notice Of Intent To Levy And Notice Of Your Right To A Hearing (notice of intent to levy) concerning petitioner’s unpaid tax liabilities for the years 1984 through 1988.3 The notice of intent to levy was mailed to petitioner at his last known address. See sec. 6330(a)(2)(C). Petitioner actually received the notice of intent to levy on October 27, 1999, as reflected by the U.S. Postal Service Form 3811, Domestic Return Receipt, that was signed at the time that the notice was 2 The notice required by sec. 6320(a) listed petitioner’s tax liabilities as $19,372.79, $715.29, $15,010, $1,618.23, and $2,189.94 for the years 1984, 1985, 1986, 1987, and 1988, respectively. 3 The notice of intent to levy stated that petitioner owed amounts from prior notices, additional penalties, and interest totaling $24,198.16, $886.24, $18,939.59, $2,053.57, and $2,797.52 for the years 1984, 1985, 1986, 1987, and 1988, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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