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Respondent assessed petitioner’s tax liabilities for 1992
and 1993 on November 26 and October 1, 2001, respectively; the
assessments amounted to $15,779 for 1992 and $6,092 for 1993.
On April 15, 2002, respondent sent petitioner Notices of
Intent to Levy for 1992 and 1993. On May 30, 2002, petitioner
sent respondent Form 12153, Request for a Collection Due Process
Hearing, in which he contested the collection proceedings with
respect to the years at issue and requested a section 6330
hearing (hearing). In his statement of reasons for disputing
respondent’s actions, petitioner asserted that his liabilities
were discharged in the bankruptcy proceedings, and that “[t]he
Service has for over 2 years constructive notice of my
situation.” On November 12, 2002, respondent held a telephonic
hearing with petitioner.
On January 17, 2003, respondent sent petitioner a Notice of
Determination, stating there was no record that petitioner’s
liabilities were discharged in bankruptcy and indicating
respondent’s intent to proceed with the levy with respect to the
years at issue.5
Petitioner filed his amended petition contesting the Notice
of Determination with this Court on February 26, 2003. In the
5 The Notice of Determination stated, in the section
captioned “Issues Raised by the Taxpayer” that “[y]ou contend
that the liabilities at issue were discharged in bankruptcy, but
there is no record of that.”
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Last modified: May 25, 2011