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period during which the hearing and appeals thereof are pending.
Sec. 6330(e)(1).
The deficiencies and additions to tax for 1988 and 1989 were
assessed on May 2, 1994. These assessments were timely because,
in light of petitioner’s failure to file returns for these years,
pursuant to section 6501(c)(3) respondent could assess the taxes
for 1988 and 1989 at any time. Respondent sought to levy on
petitioner’s property on or about May 6, 2002--well within the
10-year period of limitations. On May 30, 2002, the period of
limitations on collection for 1988 and 1989 was suspended by
petitioner’s hearing request. Sec. 6330(e)(1). The period of
limitations on collection for 1988 and 1989 remains suspended
during this proceeding. Id. Accordingly, the period of
limitations on collection for 1988 and 1989 has not expired.
Petitioner has failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
collection action, or offer alternative means of collection.
These issues are now deemed conceded. See Rule 331(b)(4).
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011