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By letter dated April 5, 2002, Appeals Officer Brenda J.
Dodson advised petitioner that she had been assigned petitioner’s
case, and she explained the objective of a hearing under section
6330. Ms. Dodson also stated the following with respect to
petitioner’s explanation of her disagreement with the proposed
collection action set forth in Form 12153:
Based on your statement on the Form 12153, you are
disputing the proposed levy action and that you had any
taxable income for the periods in question. Based upon
my review of the case administrative file and reviewing
a transcript of the account in question it indicates
assessments and balances due for the tax periods ending
December 31, 1993 and December 31, 1994. You were
afforded the opportunity to dispute the tax assessments
upon issuance of the Notice of Deficiency. This notice
afforded you 90 days to petition the United States Tax
Court to contest the proposed tax determination. You
did not exercise this right, prompting a default
resulting in the assessments. Since you did not
petition the United States Tax Court during this 90-day
period you are not entitled to any further hearing
relating to the amount of the liability for the 1993 or
1994 year under the Collection Due Process Hearing
procedures.
Ms. Dodson also advised petitioner of collection alternatives but
pointed out that two of those alternatives, an installment
agreement and the offer in compromise, required that the
taxpayer’s filing obligations be current. Ms. Dodson emphasized
that petitioner had not filed Federal income tax returns for any
of the years 1995 through 2000. She advised petitioner that
before the Service could evaluate any collection alternative,
petitioner must submit current financial information, must
indicate the monthly installment payment petitioner believed she
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Last modified: May 25, 2011