Gloria Pomerantz - Page 4

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          lien notice, Mr. Brown submitted to respondent a timely request             
          for an administrative hearing.                                              
               On November 5, 2004, petitioner submitted to respondent Form           
          433-A, Collection Information Statement for Wage Earners and                
          Self-Employed Individuals, and Form 433-B, Collection Information           
          Statement for Business.                                                     
               On December 8, 2004, Settlement Officer Elsie Stewart of               
          respondent’s Appeals Office in Plantation, Florida, held a                  
          telephonic conference with Mr. Brown and petitioner regarding               
          petitioner’s case.  Mr. Brown asserted that the assessments for             
          1995 and 1996 should be abated because they were:  (1) Incorrect;           
          (2) entered without issuance of a statutory notice of deficiency;           
          and (3) entered after the expiration of the normal 3-year period            
          of limitations.                                                             
               On February 18, 2005, respondent’s Appeals Office mailed to            
          petitioner a Notice Of Determination Concerning Collection                  
          Action(s) Under Section 6320 and/or 6330, sustaining the filing             
          of the notice of Federal tax lien against petitioner.                       
               On March 17, 2005, petitioner timely filed with the Court a            
          petition challenging respondent’s notice of determination.2                 
          Petitioner alleged in the petition that respondent erred in                 
          determining that she could not challenge the existence or amount            



               2  At the time that the petition was filed, petitioner                 
          resided in Ft. Lauderdale, Fla.                                             




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