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and statutory additions. Petitioner received the notice. On
January 13, 2002, on Form 12153, Request for a Collection Due
Process Hearing, she requested a hearing with respondent’s
Appeals Office for the years 1993 through 1998.4 The request
asserted that the respondent's findings were incorrect. No
spousal defenses or collection alternatives were alleged.
In due course, an Appeals Office hearing was held with
petitioner by telephone on September 10, 2002. Respondent
thereafter denied relief and issued a Notice of Determination
Concerning Collection Actions Under Section 6320 and/or 6330 on
October 15, 2002. The notice summarized the determination as
follows: “Our determination is that the proposed levy action is
appropriate.” An attachment to the notice, Relevant Issues
Presented by the Taxpayer, addressed petitioner’s position as
follows:
The sole issue you raised was that you disagree with
the IRS audit assessments.
You had a previous opportunity for an Appeals
conference after your administrative claims were denied.
Because you had a previous opportunity for an Appeals
conference concerning both liabilities, � 6330 precludes you
from challenging the underlying tax liabilities in this
case.
4 The petition challenges only the 1993 and 1994 tax
liabilities. The record does not reflect the status of the other
years for which petitioner requested a hearing.
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Last modified: May 25, 2011