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In Clawson v. Commissioner, supra, the notice of
determination was issued less than 3 months after the taxpayers
requested a collection hearing and only 9 days after the
telephonic collection hearing was conducted. In Manjourides v.
Commissioner, supra, less than 3 weeks passed between the
telephonic collection hearing and the issuance of the notice of
determination. In the instant case, the notice of determination
was issued more than 6 months after the estate requested a
collection hearing. The record reflects that Mr. Feist had the
estate’s case under consideration starting sometime between
September 1 and October 22, 2004. The telephonic collection
hearing was held on December 17, 2005, and the notice of
determination was issued approximately 3 weeks later on January
7, 2005.
In total, Mr. Feist had the estate’s case under
consideration for at least 2 months and as many as 4 months.
While Mr. Feist may have been predisposed to an expeditious
conclusion of the estate’s case, the Court sees nothing wrong
with that, given the facts of the instant case. See Morlino v.
Commissioner, supra. Suffice it to note that the determined
deficiency to be collected was $717,790, plus interest, and that
as of March 10, 2004, the total amount due was $1,650,674.72.
Due to questionable investments and other factors, including
legal fees contesting this very tax deficiency, the estate had
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Last modified: November 10, 2007