Llwellyn Greene-Thapedi - Page 4

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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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