Llwellyn Greene-Thapedi - Page 5

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          respondent’s Appeals Office sustained the proposed collection               
          action.6                                                                    
          Tax Court Petition                                                          
               On June 22, 2001, petitioner filed her petition in this                
          Court.7  The petition disputed, among other things, interest and            
          penalties with respect to her 1992 income tax liability and                 
          requested this Court to order respondent to credit or refund what           
          she alleged to be her tax overpayment for 1992.  The petition               
          also alleged that petitioner had failed to receive a meaningful             
          Appeals Office hearing as required by section 6330.                         
          Respondent’s Motion for Partial Summary Judgment                            
               On October 17, 2002, respondent filed a motion for partial             
          summary judgment with respect to the issue of whether petitioner            
          was afforded the opportunity for an Appeals Office administrative           
          hearing under sections 6320 and 6330.  By Order dated February              
          25, 2003, this Court granted respondent’s motion for partial                


               6 The Notice of Determination also sustained a separate                
          collection action for petitioner’s 1997 taxable year.  As                   
          explained in the following note, that matter is now moot.                   
               7 The original petition included taxable years 1991, 1992,             
          and 1997.  By Order dated Sept. 13, 2001, this Court granted                
          respondent’s motion to dismiss for lack of jurisdiction as to               
          taxable year 1991 on the ground that petitioner had not been                
          issued a notice of determination with respect to that year.  By             
          Order dated Feb. 24, 2003, this Court dismissed the collection              
          action as to taxable year 1997 as being moot, on the ground that            
          respondent had conceded that the disputed 1997 tax liability had            
          not been assessed and that respondent had erred in issuing a                
          final notice of intent to levy with respect to the 1997 taxable             
          year.                                                                       




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