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dismissal order was not appealed and became final on September
25, 2000.
On November 20, 2000, respondent assessed income tax of
$56,771 and interest of $456,023.09 and sent petitioner a notice
of balance due.7 On November 29, 2001, respondent issued a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing. On December 14, 2001, petitioner timely submitted Form
12153, Request for a Collection Due Process Hearing, requesting a
hearing under section 6330 (the hearing).
On July 10, 2002, petitioner’s counsel attended the hearing
conducted by Appeals Officer Joann Mares. At the hearing,
petitioner’s counsel argued that the statutory limitations period
for assessment (the limitations period) had expired before
respondent assessed petitioner’s 1980 income tax liability.
Petitioner’s counsel raised no other issues at the hearing. With
respect to alternative collection methods, petitioner’s counsel
expressed interest in discussing an installment agreement at a
later date if Appeals Officer Mares determined that the
limitations period had not expired before respondent’s
assessment. Petitioner’s counsel did not provide any financial
information at the hearing or propose an actual installment
agreement to Appeals Officer Mares.
7The amount of the assessment was reduced by payments and
credits totaling $140,944.67 to arrive at the balance due.
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