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On July 24, 2000, respondent assessed petitioner’s tax, as
well as a penalty under section 6662(a) and interest as provided
by law, for her taxable year 1998. (We shall refer to those
assessed amounts, as well as interest as provided by law accrued
after July 24, 2000, as petitioner’s unpaid liability for 1998.)
On July 24, 2000, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid liability for
1998.
On October 12, 2000, respondent issued to petitioner a final
notice of intent to levy and notice of your right to a hearing
(notice of intent to levy) with respect to the frivolous return
penalty under section 6702 regarding her 1998 return.
On May 30, 2001, respondent issued to petitioner a notice of
Federal tax lien and your right to a hearing (notice of tax lien)
with respect to both petitioner’s unpaid liability for 1998 and
the frivolous return penalty under section 6702 regarding her
1998 return.
On or about June 25, 2001, in response to the notice of
intent to levy and the notice of tax lien, petitioner filed Form
12153, Request for a Collection Due Process Hearing (Form 12153),
and requested a hearing with respondent’s Appeals Office (Appeals
Office). Petitioner attached, inter alia, a seven-page document
to her Form 12153 (petitioner’s attachment to her Form 12153).
That document stated in pertinent part:
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Last modified: May 25, 2011