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Unless otherwise indicated, all section references are to
the Internal Revenue Code for the years in issue.
Background
The following facts are established by the record.
On April 20, 2000, respondent, in connection with
petitioner’s unpaid assessed Federal income tax liabilities for
1990, 1991, and 1992 in the total cumulative amount of $71,385
(including penalties and accrued interest), issued to petitioner
a notice of intent to levy in conformity with the notice
requirements of section 6330(a).
On May 11, 2000, petitioner requested a collection hearing
before respondent’s Appeals Office regarding respondent’s
proposed levy. As of May 11, 2000, petitioner had not filed his
Federal income tax returns for 1993 through 1999.
In the fall of 2000, respondent’s Appeals Office mailed to
petitioner and to petitioner’s representative a number of letters
inviting petitioner to a face-to-face meeting to discuss
respondent’s proposed levy. Rather than attend a meeting with
respondent’s Appeals Office, petitioner’s representative talked
to respondent’s Appeals Office over the telephone, and on
October 25, 2000, petitioner submitted to respondent’s Appeals
Office an alternative to respondent’s proposed levy, namely, an
offer in compromise.
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Last modified: May 25, 2011