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in a timely manner, such notice was valid.” Smith v.
Commissioner, 114 T.C. at 492.
In the present case, respondent’s failure to follow section
3501(a) resulted in prejudice to petitioner by causing her to
fail to realize that she had rights to relief under section 6015
until more than 2 years after respondent applied her refund.
Unlike the notices of deficiency in Rochelle and Smith, which
notified the taxpayers of the 90-day period and the right to
petition the Tax Court, the notice of offset in the present case
did not give petitioner any information about her rights under
section 6015.
To reflect the foregoing,
An appropriate order will
be issued.
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Last modified: May 25, 2011