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taxes, penalties, and interest totaling $26,169.72 and $25,040.72
for 1991 and 1992, respectively.
On July 15, 1999, petitioner submitted requests for
collection due process hearings for 1991 and 1992 (the requests).
In the requests, petitioner states his basis for the hearing as
follows: “I deny that I had ‘income’ for the year of 1991 [1992]
that is the subject of A tax.”
On January 31, 2000, in response to the requests, Appeals
Officer Jose Gonzales sent a letter to petitioner (the letter).
Among other things, the letter informs petitioner that, since
petitioner had received the notice of deficiency, petitioner
could not, under section 6330, appeal his tax liability for 1991
and 1992. The paragraph of the letter preceding the valediction
states:
If you wish to make arrangements to pay the tax
for 1991 and 1992 please provide Forms 433A and/or 433B
or if you have other collection alternatives you would
like to discuss, such as Installment Agreements or
Offer-In-Compromise, contact me by February 15, 2000.
This will be your opportunity for a hearing. For the
reasons stated above I will not discuss the liabilities
for 1991 and 1992 unless it pertains to filing correct
returns due to IRC �6330(c)(2)(B). If I receive no
response I will send a determination letter providing
your judicial rights. I can be reached at the
telephone number shown above.
Petitioner did not reply to the letter or otherwise contact
Appeals Officer Gonzales prior to February 15, 2000.
On February 24, 2000, respondent mailed the notice to
petitioner. In part, the notice states: “We have reviewed the
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