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Hearing, requesting a hearing with respect to all 5 taxable
years. Petitioner’s Form 12153 stated: “I believe this bill is
incorrect. These taxes were never assessed.”
On April 22, 2002, petitioner and his representative
attended a hearing before Appeals Officer Serena Wong. At the
hearing, petitioner contended that respondent had not assessed
the income tax liabilities.
On October 11, 2002, the Appeals Office sent to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination). In the
notice of determination, the Appeals Office determined that
petitioner’s income tax liabilities were timely assessed, and the
assessments were “properly based on established law, policy and
procedure.”
On October 30, 2002, petitioner’s petition contesting
respondent’s determination was filed in this Court. In the
petition, petitioner alleged that “the Internal Revenue Service
abused its discretion in making the findings and conclusions it
did and abused its discretion in rejecting petitioner’s offer in
compromise.”
We held a trial in this case on October 22, 2003, at which
petitioner testified. On September 20, 2004, we filed our
Memorandum Opinion in Kun I in which we rejected petitioner’s
contention that the income tax liabilities had not been timely
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