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deficiency and $880 penalty. Petitioner did not petition this
Court to redetermine the deficiency or penalty.
Petitioner paid only a portion of the agreed-upon tax and
penalty. On July 28, 2004, respondent sent petitioner a Final
Notice of Intent to Levy (the levy notice) for collection of
petitioner’s unpaid 1998 balance. On August 23, 2004, Alan
submitted on petitioner’s behalf Form 12153, Request for a
Collection Due Process Hearing. Notwithstanding that Alan had
previously executed Form 870 agreeing to the immediate assessment
of the $1,212 tax that was in fact assessed on May 27, 2002, on
the Form 12153 Alan complained that he had never been given an
explanation for the May 27, 2002, assessment.
The settlement officer sent petitioner materials explaining
the basis for the disputed assessment; she directed petitioner to
submit certain information if petitioner wished her to consider a
collection alternative; and she scheduled a telephone conference
for May 24, 2005. By letter dated May 11, 2005, Alan requested
that the telephone conference be rescheduled, stating that he
wished to present “new evidence” in a face-to-face conference.
Petitioner’s case was reassigned to an Appeals officer. By
letter dated June 23, 2005, the Appeals officer advised that
petitioner was not entitled to dispute the underlying liability,
having previously agreed to it; she offered to schedule a face-
to-face hearing to consider payment options. By letter dated
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Last modified: May 25, 2011