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an enrolled return preparer, no information was provided to Mr.
Rehm at the conference. Mr. Rehm communicated to Officer Heidle
the desire of petitioners to reopen the audit of their 2001
return.
On December 29, 2005, Officer Heidle held a face-to-face
conference with petitioner Jennifer Bond (Mrs. Bond) and Mr.
Rehm. Mrs. Bond raised questions regarding petitioners’ tax
liability for 2001 and reiterated petitioners’ request to reopen
the audit of their 2001 return. Officer Heidle informed Mrs.
Bond that petitioners were precluded from contesting their
underlying tax liability for 2001 because petitioners had already
been given an opportunity to do so when they received the October
27, 2004, notice of deficiency, which Mrs. Bond acknowledged
receiving.
On April 12, 2006, Officer Heidle sent petitioners a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330. Officer Heidle determined that petitioners
were precluded from contesting their underlying tax liability and
concluded that respondent could proceed with the proposed
collection action.
On May 16, 2006, the petition was filed. In their petition,
petitioners raised arguments relating only to their underlying
tax liability for 2001.
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