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Respondent issued Notices of final partnership
administrative adjustments (FPAAs) to SGE 84-4 for its 1984
through 1986 taxable years.6 After completion of the
partnership-level proceedings, respondent sent petitioners a Form
4549A-CG, Income Tax Examination Changes, reflecting changes made
for petitioners’ 1981 through 1988 tax years on July 30, 1998.
Respondent determined deficiencies in petitioners’ income tax of
$8,098, $3,405, $941, $8,421, $14,034, $7,714, $3,239, and $413,
respectively.
On August 17, 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 1988.
On September 14, 2001, petitioners submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioners argued
that the proposed levies were inappropriate and that an offer-in-
compromise should be accepted.
On May 9, 2002, petitioners submitted a letter (the May 2002
letter) to respondent’s Appeals Office outlining their position
with respect to the proposed collection action. Petitioners
alleged that they were victims of Hoyt’s fraud and asserted
6 SGE 84-4 was also issued an FPAA for 1987. However, it
does not appear that the adjustments made to petitioners’ income
tax liability for the 1981-88 tax years arose from partnership
level proceedings relating to the 1987 FPAA.
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