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of claim disallowance (Form 2297), the period for
bringing suit began to run on the date you filed the
waiver.
In an attachment to the letter, respondent explained the basis
for the disallowance. Petitioner did not file suit with the
United States District Court or the United States Court of
Federal Claims.
On February 22, 2001, respondent sent to petitioner a Final
Notice of Intent to Levy and Notice of Your Right to a Hearing.
The amounts listed as owing were set forth on the second page of
the letter as follows:
TYE Unpaid Amount Additional
Amount
Dec. 31 from Prior Notices Penalty & Interest You Owe
1992 $23,074.30 $31,031.44 $54,105.74
1993 32,723.25 29,164.71 61,887.96
1994 32,639.49 9,996.45 42,635.94
1995 33,669.86 10,483.24 44,153.10
1996 31,933.14 11,484.01 43,417.15
1997 22,862.00 10,740.11 33,602.11
Total: 279,802.00
Petitioner requested a hearing by letter dated March 19, 2001.
On June 14, 2002, an IRS revenue officer had a telephone
conference with petitioner’s representative concerning the
February 22, 2001, letter from the IRS. On April 7, 2003,
respondent sent petitioner a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and or 6330 (notice of
determination), with respect to the taxable years 1992 through
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Last modified: May 25, 2011