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Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206,
112 Stat. 771, which requires the IRS to include in--
any first letter of proposed deficiency which allows
the taxpayer an opportunity for administrative review
in the Internal Revenue Service Office of Appeals an
explanation of the entire process from examination
through collection with respect to such proposed
deficiency, including the assistance available to the
taxpayer from the National Taxpayer Advocate at various
points in the process.
Petitioner received Notices of Federal Tax Lien and timely
requested and received a section 6320(b) hearing. After he
received respondent’s Notice of Determination, he timely filed a
petition for judicial review of respondent’s determination. The
essence of RRA 1998 section 3504 is to provide the taxpayer with
notice of his or her rights throughout the appeals and collection
process. Since petitioner knew of, and pursued, his right to
administrative and judicial review under section 6320, the
failure of the IRS to provide this information did not prejudice
or harm petitioner in any way.
3. Petitioner’s Request for Documents
Petitioner contends that the Appeals officer did not provide
him with documents before the hearing that he had requested and
argues that this prevented him from presenting his case or
effectively examining documents.
Petitioner requested a copy of the Form 23 C. Respondent
sent him a copy of the record of assessment 2 months before the
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Last modified: May 25, 2011