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Background
On January 5, 2006, respondent issued to petitioner a
Decision Letter Concerning Equivalent Hearing Under Section 6320
and/or 6330 of the Internal Revenue Code (decision letter)
regarding proposed collection action for petitioner’s tax years
1995, 1996, and 1997.1 In the decision letter, respondent’s
Office of Appeals informed petitioner that her due process
hearing request was not filed within the time prescribed under
section 6320 and/or 6330. Respondent’s Office of Appeals further
informed petitioner that she received a hearing equivalent to a
due process hearing except that there was no right to dispute a
decision by the Appeals Office in court under sections 6320
and/or 6330. In the decision letter, the Appeals Office
sustained the proposed collection action. On January 31, 2006,
petitioner sent to the Court a document, which states in relevant
part:
Dear Tax Court Judge,
The Collection Due Process (hereafter “CDP”) Hearing
that I requested has been decided. I need your
assistance regarding a Notice of Determination I
received from the Internal Revenue Service for the tax
year [sic] 1995, 1996 and 1997. The Internal Revenue
Service (hereafter “IRS”) DID NOT grant me a CDP
Hearing, which I have requested. The Hearing they
attempt [sic] to conduct was unfair and biased. I was
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011