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Petitioner’s hearing before Appeals was conducted via telephone
conversations on February 5 and February 19, 2002, at which times
collection alternatives for the $12,239 balance for 1994 were
discussed. The Appeals officer also considered and allowed some
itemized deductions for 1994.
Petitioner advised the Appeals officer during the February
19, 2002, telephonic conversation that she did not wish to
further pursue collection alternatives until she sought review by
the Tax Court of respondent’s partial denial of relief from
liability under section 6015. Petitioner did not submit her
financial information to the Appeals officer.
On March 1, 2002, the Appeals office mailed petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 concluding that respondent may proceed
with collection of the remainder of petitioner’s 1994 tax
liability.
On March 19, 2002, petitioner filed a petition with this
Court for review of respondent’s determination to proceed with
collection. In that petition she generally alleged that she
disputed respondent’s determination. On April 15, 2002, she
amended her petition and specifically alleged error with respect
to the underlying merits of the $12,239 balance for the 1994
year. No error was alleged with respect to respondent’s
determination under section 6015 or with respect to the adequacy
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Last modified: May 25, 2011