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proceed with collection by way of levy for the years 1987 through
1992 and 1997. The decision letter stated in pertinent part:
Your due process hearing request was not filed within
the time prescribed under Section 6320 and/or 6330.
However, you received a hearing equivalent to a due
process hearing except that there is no right to
dispute a decision by the Appeals Office in court under
IRC Sections 6320 and/or 6330.
On October 6, 2000, the Appeals Office issued to petitioner
Dorothy Moorhous a Notice of Determination Concerning Collection
Action(s) Under Sections 6320 and/or 6330 (notice of
determination). The notice of determination stated that
petitioner Dorothy Moorhous was not eligible for an offer-in-
compromise. The notice of determination further stated that
respondent would proceed with collection with respect to
petitioner Dorothy Moorhous’ tax liabilities for the years 1989
through 1992 and that petitioner Dorothy Moorhous would have 30
days to file a petition with the Tax Court contesting the matter.
On October 16, 2000, petitioners filed with the Court a
joint Petition For Lien Or Levy Action Under Code Sections
6320(c) Or 6330(d). See Rule 331(b). The petition states in
pertinent part that petitioners challenge petitioner Dudley
Moorhous’ individual liabilities for the years 1987 and 1988 and
petitioners’ joint liabilities for the years 1989 through 1992
and 1997. The petition includes an allegation that respondent
erred in failing to decide the offer-in-compromise that
petitioners filed with respondent in 1997.
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Last modified: May 25, 2011