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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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Last modified: May 25, 2011