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assessments); (2) respondent had given petitioner notice of the
return assessments as required by section 6303; (3) that notices
of deficiency were not required with respect to the return
assessments for 1984 through 1987 because the assessments covered
amounts reported as due on petitioner’s returns; and (4) that the
Form 900 executed by petitioner was valid, extending the period
of limitations for collection for the years 1984 through 1987 to
December 31, 2000.
In his petition in the instant case, petitioner asserts:
(1) That the proposed collection is time-barred; (2) that
respondent failed to properly assess his tax liabilities or
notify him of the assessments for the years 1984 through 1987;
(3) that he did not receive notices of deficiency for the years
in issue; and (4) that respondent failed to conduct a fair
hearing (a) by refusing to explain how the proposed levy was
balanced with petitioner’s interests; (b) by directing the
Appeals officer not to address the “23C Summary Record of
Assessment” issue, (c) by refusing to grant a hearing to
petitioner’s spouse; and (d) by refusing to explain why Form 4340
was given “evidentiary precedence” over petitioner’s individual
master file.
Discussion
Section 6331(a) provides that if any person liable to pay
any tax neglects or refuses to pay such tax within 10 days after
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Last modified: May 25, 2011