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The record establishes that the Appeals Office properly
verified that all applicable laws and administrative procedures
were followed. Settlement Officer Jacobi had no prior
involvement with respect to the unpaid tax liabilities before the
section 6330 hearing. Settlement Officer Jacobi determined that
the assessments were both timely and valid by examining:
Respondent’s computerized records and audit files; petitioner’s
1994 and 1995 tax returns; a copy of the notice of deficiency
mailed to petitioner; and Form 3877 showing the date the notice
of deficiency was mailed to petitioner at his last known address.
Settlement Officer Jacobi also determined that petitioner had
received notice of his rights as a taxpayer through various IRS
publications sent with the notice of deficiency including IRS
Publications 1, 5, 594, and IRS Notice 1214 (listing the name and
phone number of the local Taxpayer Advocate Service office), and
that petitioner failed to timely petition the Tax Court to
contest the notice of deficiency. Finally, petitioner did not
3(...continued)
properly mailed a notice of deficiency to petitioner at his last
known address. Petitioner failed to petition the Tax Court
within 90 days as required by sec. 6213(a). On Jan. 3, 2000,
respondent assessed against petitioner the income tax
deficiencies, additions to tax, and penalties for the taxable
years 1994 and 1995 reflected in the notice of deficiency mailed
to petitioner on Aug. 11, 1999. Because the limitations period
under sec. 6503(a) was tolled, respondent assessed the
liabilities well within the limitations period.
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Last modified: May 25, 2011