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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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