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the deficiencies in tax and the section 6621(c) interest as a
computational adjustment, no notices of deficiency were issued.
On March 7, 2002, respondent issued petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing (final notice). In addition to petitioner’s outstanding
tax liabilities for 1982 through 1988, the final notice included
an unpaid amount of $59 from 1993 and interest of $164 and $692
for 1993 and 1997, respectively.7 The final notice indicated
that, as of April 6, 2002, petitioner owed $213,258, inclusive of
interest.
On March 18, 2002, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioner
indicated that he would be pursuing an offer-in-compromise based
alternatively on doubt as to collectibility with special
circumstances or effective tax administration. Petitioner also
argued that, because he had not had a previous opportunity to
dispute the imposition of section 6621(c) interest, it was a
proper subject for review in the section 6330 hearing.
Petitioner’s case was assigned to Settlement Officer Linda
Cochran (Ms. Cochran). Ms. Cochran initially scheduled a
telephone section 6330 hearing on April 6, 2004. Petitioner’s
representative, Terri A. Merriam (Ms. Merriam), requested that
7 Details regarding petitioner’s 1993 and 1997 tax years
are not in the record.
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Last modified: May 25, 2011