- 7 - petitioner’s physical illness and the resulting cloud on title to petitioner’s residence, petitioner’s only significant asset). Petitioner makes no other argument with regard to the propriety of respondent’s notice of determination. On February 13, 2002, at the hearing before us on respondent’s motion for summary judgment, petitioner’s counsel acknowledged that petitioner’s ill health was not recent but had extended back over 20 years. Further, at that hearing, in response to a question from the Court as to why hardship had not been raised at petitioner’s collection hearing or otherwise brought to the attention of respondent’s Appeals Office, petitioner’s counsel acknowledged that he had had an opportunity at the collection hearing to raise hardship but that he had chosen not to do so. Discussion Statute of Limitations Respondent argues that under section 6330(c)(4) and under the principle of collateral estoppel petitioner is precluded in this case from asserting that no effective extension to extend the period of limitations on collection of petitioner’s unpaid tax liability for 1980 was executed by petitioner. We agree with respondent. Section 6330(c)(4) expressly provides that taxpayers, at collection hearings before respondent’s Appeals Office, may notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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