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taxable year 1999. At that hearing, the settlement officer also
gave petitioner a copy of Pierson v. Commissioner, 115 T.C. 576
(2000), and explained the warning of the Court in that Opinion
with respect to section 6673(a)(1).
On November 4, 2003, the Appeals Office issued to petitioner
a notice of determination concerning collection action(s) under
section 6320 and/or 6330 (notice of determination). That notice
of determination stated in pertinent part:
Summary of Determination
Appeals determination is that Compliance is upheld. No
relief is granted. You were given an opportunity to
prepare and file corrected returns and provide a com-
pleted Collection Information Statement. You failed to
file corrected returns. You did not provide any finan-
cial information on which consideration of alternatives
could be based. You raised only frivolous arguments
and were given a copy of Pierson v. Commissioner.
An attachment to that notice of determination stated in pertinent
part:
SUMMARY AND RECOMMENDATION
You requested a Collection Due Process (CDP) Hearing
with Appeals under the provisions of IRC �6330.
-The determination of Appeals is that the proposed
collection actions are appropriate and are upheld.
No relief is granted.
* * * * * * *
VERIFICATION OF LEGAL AND PROCEDURAL REQUIREMENTS:
The statute of limitations has been suspended since
12/09/2002. The Settlement Officer had no involvement
in your case prior to the assignment for the CDP Hear-
ing.
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Last modified: May 25, 2011