-8-
issued to the estate a notice of deficiency that informed it that
Christianson had rejected the protest to the extent of the
disputed deficiency portion of the section 6651(a)(1) addition to
tax. The notice of deficiency contained no determination as to
the assessed additions to tax.
9. The Hearing
Following the issuance of the notice of deficiency,
respondent resumed his administrative proceeding concerning the
request. The request was assigned to Appeals Officer Michael
Beecher. By letter dated February 9, 2005, Beecher contacted the
estate regarding the request. The letter noted that the estate
had had a previous hearing with Appeals regarding the section
6651(a)(1) addition to tax and invited the estate to raise any
other relevant issue and to provide financial information in
order for Appeals to consider collection alternatives. The
estate did not respond to the February 9, 2005, letter.
Appeals (through Christianson) determined that the lien was
not unnecessarily intrusive and on March 10, 2005, issued the
estate a notice of determination approving the lien. Appeals
(through Christianson) determined that the proposed levy was not
unnecessarily intrusive and on May 27, 2005, issued the estate a
notice of determination approving the levy.
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