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SFRs and petitioner’s failure to petition the Court to dispute
the deficiencies determined in the statutory notices.
On or about December 28, 1997, respondent’s revenue officer
Ronald Mele (Revenue Officer Mele) confirmed with postal
employees that petitioner’s previous mailing address was the Elm
Street address. On January 28, 1998, Revenue Officer Mele
confirmed with postal employees that petitioner was using his
Strawberry Hill address as his mailing address and updated
respondent’s computer records accordingly.
During a telephone conversation sometime in 1998, petitioner
instructed Revenue Officer Mele to use the post office box
address as his mailing address rather than the Strawberry Hill
address.
Respondent’s Proposed Levy
On March 8, 1999, respondent sent petitioner by certified
mail addressed to petitioner at his post office box address a
final notice of intent to levy and notice of right to a hearing.
On May 14, 1999, respondent received petitioner’s untimely Form
12153, Request for a Collection Due Process Hearing. On June 7,
1999, respondent granted petitioner a so-called equivalent
hearing under section 301.6330-1T(i), Temporary Proced. & Admin.
Regs., 64 Fed. Reg. 3413 (Jan. 22, 1999), because petitioner’s
request was untimely. On September 13, 1999, respondent’s
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Last modified: May 25, 2011