- 9 - those tax liabilities. The Court granted respondent’s motion to remand. On August 10, 2005, respondent’s Appeals Office issued to petitioner a “SUPPLEMENTAL NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330” in which respondent’s Appeals officer sustained the determination made in the notices of deficiency issued to petitioner with respect to petitioner’s income tax for the years 1990 through 1993. In his request for an administrative hearing and the amendment thereto with respect to the filing of the lien, petitioner did not raise any collection alternatives. Petitioner asserted that respondent did not mail notice and demand for payment to petitioner’s last known address, that the Form 5213 which he filed was invalid because it was not submitted to respondent within 60 days of receipt by petitioner, and therefore that the period of limitations had expired for the years 1990 and 1991. In the notice of determination, respondent’s Appeals officer determined that notice and demand for payment had been mailed to petitioner’s last known address because the notice had been mailed to the address on petitioner’s most recently filed Federal income tax return. Respondent’s Appeals officer determined that petitioner submitted the Form 5213 to respondent more than 60 days followingPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007