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On August 31, 2000, respondent’s Appeals Office mailed to
petitioner a notice of determination in which respondent’s lien
filings were sustained. In the above notice of determination,
with regard to the statute of limitations contention asserted by
petitioner, respondent’s Appeals Office concluded that the period
of limitations on collection had not expired. Also in the notice
of determination, respondent’s Appeals Office concluded that,
because petitioner did not wish to discuss any collection
alternatives and because petitioner did not raise any concerns
regarding collection other than the statute of limitations, the
lien filings balanced the need for efficient collection of taxes
with the legitimate concerns of petitioner that the lien filings
be no more intrusive than necessary.
On September 29, 2000, petitioner timely filed a petition
herein for our review of the above notice of determination. In
his petition, petitioner reiterated his claim that the period of
limitations on collection had expired with respect to his tax
liability for 1980 and therefore that respondent’s lien filings
were untimely and improper. The basis for petitioner’s statute
of limitations contention was that he allegedly had not executed
an extension of the period of limitations on the collection of
petitioner’s unpaid tax liability for 1980.
Also in his petition, petitioner, for the first time, raised
hardship as an objection to respondent’s lien filings (namely,
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Last modified: May 25, 2011