Dennis Burbridge and Rosemary Burbridge - Page 4

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          Form 1099-R.  Respondent’s notice of deficiency was mailed only             
          to, and received only by, petitioner.                                       
               Petitioner did not file a petition in this Court with regard           
          to the above notice of deficiency.  On February 24, 1997,                   
          respondent assessed the $9,285 income tax deficiency set forth in           
          the notice of deficiency against both petitioners.                          
               On June 16, 2000, respondent mailed to both petitioners a              
          notice of intent to levy relating to the above 1993 tax                     
          assessment.  On July 14, 2000, petitioner submitted to respondent           
          a request for a section 6330 hearing.                                       
               On January 24, 2002, respondent’s Appeals officer mailed to            
          petitioners a letter notifying petitioners that respondent had              
          received petitioners’ request for a hearing.  On January 29,                
          2002, petitioner contacted the Appeals officer and scheduled a              
          hearing.  On February 5, 2002, petitioner and the Appeals officer           
          discussed the notice of intent to levy over the telephone                   
          (telephone conference).3                                                    
               During the telephone conference, petitioner attempted to               
          challenge the underlying tax liability by claiming that the total           
          $109,737 annuity distribution had been included on his deceased             


               3 Originally, the Appeals Office hearing was scheduled to be           
          held in respondent’s office on Feb. 5, 2002, but, on the morning            
          of Feb. 5, petitioner called the Appeals officer and stated that            
          he could not attend the hearing at respondent’s office.  The                
          Appeals officer suggested that they could discuss the notice of             
          intent to levy over the telephone, to which petitioner agreed and           
          which they proceeded to do.                                                 




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