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credits and payments relating to 1982, and calculated the balance
due at the time the lien was filed; (2) two consecutive
bankruptcy petitions extended the collection period; (3) Form 900
was signed prior to expiration of the collection period; (4) the
installment agreements were not in effect due to petitioners’
default; and (5) the collection periods relating to 1982 and 1983
had not expired.
By Notice of Determination Concerning Collection Action(s)
Under Section 6320 and/or 6330, dated November 15, 2001,
respondent determined that the collection period relating to
petitioners’ 1982 and 1983 tax liabilities had not expired,
petitioners may not claim additional deductions with respect to
1982 and 1983, petitioners offered no collection alternatives,
and, thus, it was appropriate to proceed with collection.
On January 25, 2002, petitioners, while residing in Lutz,
Florida, filed an amended petition in which they contend that the
settlement officer improperly refused to consider petitioners’
alleged entitlement to additional deductions relating to 1982 and
1983, petitioners’ consent to an extension of the collection
period was invalid because Form 900 was signed after the
collection period had expired, and respondent miscalculated their
unpaid tax liabilities.
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Last modified: May 25, 2011