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Revenue Service (IRS) notified petitioner of disallowance of the
refund claim and of his right to contest the denial by filing a
lawsuit in the U.S. District Court or U.S. Court of Federal
Claims.
With respect to 1999, the IRS examined petitioner’s filed
return and issued a statutory notice of deficiency. Petitioner
did not file a petition with this Court in response to the notice
of deficiency, and respondent assessed the tax, an addition to
tax, and interest for 1999 on November 19, 2001. Notices of
balance due were promptly sent to petitioner with respect 1999.
Thereafter, on August 5, 2002, respondent issued to
petitioner a Final Notice of Intent To Levy and Notice of Your
Right To a Hearing regarding his unpaid liabilities for 1998 and
1999. Petitioner timely submitted to respondent a Form 12153,
Request for a Collection Due Process Hearing, setting forth his
disagreement with the levy, as follows: “NOT LIABLE, MORE
DETAILS TO FOLLOW”.
By a letter dated February 20, 2003, Julieanne M. Petersen,
the Appeals officer to whom petitioner’s case had been assigned,
scheduled a hearing for March 20, 2003, in Las Vegas, Nevada.2
The letter briefly outlined the hearing process, advised that
audio or stenographic recording of hearings was not allowed, and
2 The explanation attached to the Apr. 23, 2003, notice of
determination apparently refers in error to Mar. 28, 2003, as the
date initially scheduled for the requested hearing.
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Last modified: May 25, 2011