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1983. As a result of these losses and credits, petitioners
reported overpayments of tax for 1981 through 1987 and received
refunds in the amounts claimed.
Respondent issued notices of final partnership
administrative adjustments (FPAAs) to TBS 84-2 for its 1984 and
1985 taxable years, to DGE 84-2 for its 1986 taxable year, and to
DGE 85-4 for its 1985 and 1986 taxable years.6 After completion
of the partnership-level proceedings, respondent determined
deficiencies in petitioners’ income tax for their 1981 through
1987 tax years.
On August 21, 2001, respondent issued petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). The final notice included petitioners’
outstanding tax liabilities for 1981 through 1987.
On September 12, 2001, petitioners submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioners argued
that the proposed levies were inappropriate, that an offer-in-
compromise should be accepted, and that Mr. Andrews was entitled
to innocent spouse relief under section 6015.
Petitioners’ case was assigned to Settlement Officer Linda
Cochran (Ms. Cochran). Ms. Cochran scheduled a telephone section
6330 hearing for March 17, 2004. During the hearing,
6 The FPAAs and other information specific to TBS 84-2’s,
DGE 84-2’s, and DGE 85-4’s partnership-level proceedings are not
in the record.
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