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If you have questions or concerns, please give me a
call. I would like your reply by February 4, 2002. If
I do not hear from you by that time, I will close my
case and issue a Determination Letter that will advise
you of your client’s right to contest the determination
by filing suit in Tax Court.
Petitioner responded to the Appeals officer’s letter, by
letter sent by petitioner’s counsel to respondent on January 30,
2002, in which petitioner requested an extension of time to reply
to respondent’s January 23, 2002, letter. Petitioner’s counsel
indicated that petitioner was employed as a truck driver, and
that he was out of town. Petitioner’s counsel requested an
extension of 30 days from February 4, 2002, to review the
contents of the Appeals officer’s letter.
On April 4, 2002, respondent issued a notice of
determination for the years in issue, sustaining the amounts
sought to be collected by levy. The notice of determination
stated:
No evidence has been presented to show that the amounts
shown due are incorrect. You have not demonstrated
that any portion of these liabilities was discharged in
bankruptcy. You have not proposed a collection
alternative. The proposed collection action is
sustained.
Attachment 3193, attached to the notice of determination,
indicated that petitioner “expressed concern for the fact that
there are missing credits and for the fact that bankruptcy should
have discharged a portion of what is due.” The Appeals officer
indicated that petitioner did not question the appropriateness of
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Last modified: May 25, 2011