- 6 - On March 9, 2000, petitioner attended an Appeals Office hearing in Cincinnati, Ohio, conducted by Appeals Officer William C. Roll. On July 21, 2000, the Appeals Office mailed to petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination). The notice of determination states in pertinent part: The assessments for 1986 are invalid, and no collection action will be enforced. For 1990, the assessments are valid. In your appeal, you did not raise any alternative collection method to enforce collection, and the proposed levy should be enforced. An attachment to the notice of determination states in pertinent part: A valid notice of deficiency [for 1990] was issued, and assessments were made in accordance with legal and procedural requirements. The deficiency notice was mailed to your last known address, at the time the notice was mailed. Your failure to file current returns prevented an update of your address, so that you failed to receive notices of demand for payment. Your failure to receive the notices mailed to your last known address does not invalidate the assessments. The legal and procedural requirements for 1990 have been met. * * * * * * * It is determined that a deficiency notice for 1990 was mailed timely to your last known address. Your failure to file any tax return after 1989, and failure to cooperate in acknowledging your new address, contributed to the lack of your current address being in the files of the Internal Revenue Service. Because notices were issued to your last known address as ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011