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covering the years 1984 through 1987, which listed as the
taxpayer both himself and his spouse. In an addendum to the Form
12153, petitioner alleged four errors with respect to
respondent’s proposed collection actions: (1) That he had not
received Forms 23C for the years 1984 through 1987; (2) that he
had not received notices of deficiency for the years 1984 through
1987; (3) that the Form 900 executed by him was invalid; and (4)
that the IRS had failed to publish pertinent data concerning Form
900 in the Federal Register. Petitioner did not raise any
spousal defenses or offer any collection alternatives.
Petitioner, but not his spouse, signed the Form 12153.
Petitioner’s hearing was conducted by an Appeals officer of
respondent. A face-to-face meeting between petitioner and the
Appeals officer was held. At the hearing, petitioner raised an
additional issue to the effect that a levy served on his employer
on or about March 18, 1997, was invalid due to lack of proper
notice.
During the meeting with petitioner, the Appeals officer
provided petitioner with a MFTRA-X version of his transcript of
account. Relying on the codes contained in the MFTRA-X
transcript, the Appeals officer determined that the respondent
had properly assessed petitioner’s tax liabilities for 1984,
1985, 1986, and 1987.
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