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C. The Section 6330 Hearing
Respondent issued a Final Notice, Notice of Intent to Levy
and Notice of Your Right to a Hearing, on November 8, 2000. In
the Final Notice, respondent stated that petitioner owed
$270,087.60 for 1989, $108,044.26 for 1990, and $5,507.84 for
1999.
On December 1, 2000, petitioner sent to respondent a Form
12153, Request for a Collection Due Process Hearing. Petitioner
was incarcerated at the Wyoming Correctional Facility at that
time. He attached an explanation in which he said he had not
received the notice of deficiency and that he was not liable for
tax in the amounts stated in the notice.
One of respondent’s Appeals officers was assigned to
petitioner’s case on February 12, 2002. The Appeals officer kept
an activity log for the case in which he said: (1) The case is
very complex; (2) petitioner claims that he had no prior
opportunity to contest the underlying liability and he did not
receive the notice of deficiency; and (3) the “administrative
file indicates that a defaulted * * * [notice of deficiency] is
in [the administrative] file”.
On May 1, 2002, the Appeals officer sent a letter to
petitioner at the Wyoming Correctional Facility stating in part:
We scheduled the conference you requested on this
case for * * * [9:30 a.m., May 21, 2002, at room 1137,
290 Broadway, New York, New York]. Please let me know
within 10 days from the date of this letter whether
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