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notice of deficiency for 1990 to petitioner’s last known address.
Id. at 98-6510.2
G. Final Notice
On April 7, 1999, respondent sent petitioner a Final Notice-
-Notice of Intent to Levy and Notice of Your Right to a Hearing
with respect to petitioner’s unpaid 1986 and 1990 tax
liabilities.
H. Appeals Office Hearing
On May 7, 1999, petitioner timely filed a Form 12153,
Request for a Collection Due Process Hearing, with respect to his
1986 and 1990 taxes. In the Form 12153, petitioner indicated
that he disagreed with the notice of intent to levy with respect
to his 1986 tax liability because, among other reasons, no notice
of deficiency had been issued. With respect to his 1990 tax
liability, petitioner indicated that he disagreed with the notice
of intent to levy for the following reasons: “No notice of
assessment and demand for payment sent to last known address
within 60 days of assessment, IRS received payment, lien is
invalid, IRS lacks authority to conduct administrative seizure.”
2 Although it would appear to have been unnecessary for its
disposition of petitioner’s motion, the U.S. District Court for
the Southern District of Ohio also found that no notice of
deficiency was issued to petitioner for 1986 or 1991. McIntosh
v. United States, 82 AFTR 2d 98-6501, at 98-6503 (S.D. Ohio
1998).
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