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whether this case should be remanded to respondent’s Appeals
Office for a recorded administrative hearing. Petitioner objects
to respondent’s motion, and respondent objects to petitioner’s
motion. All section references are to the Internal Revenue Code
in effect for the year in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
Background
On June 21, 2001, respondent mailed to petitioner a
statutory notice of deficiency for the taxable period ending
December 31, 1997. Petitioner received the statutory notice, but
failed to petition this Court. On November 26, 2001, respondent
assessed petitioner’s 1997 Federal income tax deficiency.
A Form 1058, Final Notice--Notice of Intent to Levy and
Notice of Your Right to a Hearing, was sent to petitioner on
April 2, 2002. On April 9, 2002, respondent sent petitioner a
letter entitled, “Notice of Federal Tax Lien Filing and Your
Right to a Hearing under I.R.C. �6320”. Petitioner’s designated
representative timely requested an administrative hearing under
sections 6320 and 6330. Petitioner’s sole contention in the
administrative hearing request was that “there are egregious
errors that once corrected would mitigate the collection
activity.”
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Last modified: May 25, 2011