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overpayment of $248,093. At that time, petitioner also filed
returns for 1998 through 2002 that reflected tax liabilities of
$11,484 for 1998 and $22,099 for 1999 and overpayments of tax of
$132,870 for 2000, $131,289 for 2001, and $242,448 for 2002 (a
net overpayment of $473,024).
Mr. Stechel sent copies of the 1995 and 1996 returns and the
amended return for 1997 to Appeals Officer Azim. In the cover
letter, Mr. Stechel stated: “As we previously discussed, I am
enclosing a set of the returns being filed contemporaneously on
behalf of the taxpayer. I believe that these filings will render
moot the necessity for a Collection Due Process hearing. Please
call me if you have had the opportunity to review these
enclosures.”
Respondent did not accept the returns for 1995 and 1996 or
the amended return for 1997. Respondent accepted the returns for
1998 through 2004. Respondent did not credit the overpayment
petitioner claimed for 2000 because credit or refund of the
overpayment was barred by section 6511(b)(1).
On January 21, 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 levy notice against petitioner. On February 24, 2005,
petitioner timely filed with the Court a petition challenging
respondent’s notice of determination.
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