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that the balance shown on respondent’s Form CP 504 included
erroneous penalties and interest accruals.
On January 9, 2001, respondent issued petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (the Final Notice) with respect to her 1992 income tax
liabilities, showing an assessed balance of $4,992.70, and
stating that this amount did not include accrued penalties and
interest.5 Petitioner submitted another Form 12153, dated
January 17, 2001, again requesting a hearing with respect to her
1992 taxable year and stating: “I do not owe the money. Notice
improper”.
Appeals Office Hearing and Notice of Determination
The Appeals Office hearing consisted of an exchange of
correspondence and telephone conversations. During the hearing,
petitioner contended that she was not liable for any interest
accruals between December 19, 1997, and July 3, 2000, on the
ground that she had not received the December 19, 1997, notice of
balance due and was not notified of any balance due until July 3,
2000. By Notice of Determination dated May 22, 2001,
4(...continued)
premature, on the ground that petitioner had not yet received any
notice of Federal tax lien filing, final notice of intent to
levy, or notice of jeopardy levy with respect to taxable year
1992.
5 The record does not otherwise conclusively establish how
the $4,992.70 assessed balance was calculated.
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