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On October 10, 2002, the Appeals Office issued to Ms. Latos
a notice of determination with respect to, inter alia, her
taxable year 1998 (1998 notice of determination). That notice
stated in pertinent part:
Summary of Determination
Your position on the liability for the Income Tax is
without merit. You have not proposed any viable alter-
natives to enforced collection action. Without suffi-
cient response to requests for information and alterna-
tives, Appeals has determined that no choice exists but
to return the matter to the jurisdiction of the Compli-
ance Division for necessary action.
An attachment to the 1998 notice of determination stated in
pertinent part:
Attachment to 3193
Collection Due Process
Lien and Levy Issue
James E. Anderson & Cheryl J. Latos
Summary and Recommendation
* * * You submitted two Forms 12153, Request for a
Collection Due Process Hearing, in response to the
issuance of Letter 1058, Final Notice: Notice of Intent
to Levy and Notice of Your Rights to a Hearing issued
on December 5, 2001 and the filing of a Notice of
Federal Tax Lien on December 6, 2001. Your 12153
requests were received on December 12, 2001 and Decem-
ber 19, 2001 respectively. The settlement officer
conducting the hearing has had no prior involvement
with these matters. The impact of the hearing request,
on the statute of limitations, has been verified to be
proper.
The request for a collection due process hearing was
timely made and the hearing was conducted in expedi-
tious fashion at your request. Neither in your written
communication nor at the hearing, did you raise any
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Last modified: November 10, 2007