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taxable years 1991 and 1992, and that respondent was preparing to
collect this amount by levy. The notice stated that petitioner
had 30 days to request a collection due process hearing with
respondent's Appeals Office.
On November 10, 1999, petitioner filed a request for a
section 6330 hearing with respondent's Appeals Office.
On November 20, 2000, the Appeals Office conducted a hearing in
petitioner’s case.
On December 12, 2000, 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 the Appeals Office
would proceed with collection with respect to the amount due for
1991, but that petitioner was not liable for any amount for 1992.
Respondent’s determination to abate the assessments entered
against petitioner for 1992 produced a credit of $50 for that
year which respondent applied to petitioner’s outstanding tax
liability for 1991.
On January 9, 2001, petitioner filed with the Court an
imperfect Petition for Lien or Levy Action Under Section 6320(b)
or 6330(d).2 On March 26, 2001, petitioner filed an amended
petition which included nothing but frivolous and groundless
2 At the time the petition was filed, petitioner resided in
Las Vegas, Nevada.
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Last modified: May 25, 2011