- 4 - notice of intent to levy, petitioner timely filed Form 12153, Request for a Collection Due Process Hearing (petitioner’s Form 12153), and requested a hearing with respondent’s Appeals Office (Appeals Office).3 On March 15, 2006, a settlement officer with the Appeals Office (settlement officer) held an Appeals Office hearing with petitioner with respect to the notice of intent to levy. At that hearing, petitioner indicated that he was not liable for peti- tioner’s unpaid liabilities for 1995 and 1998. On April 5, 2006, the Appeals Office issued to petitioner a notice of determination concerning collection action(s) under section 6320 and/or 6330 (notice of determination). That notice stated in pertinent part: “Collection is sustained. No collec- tion alternatives were offered for consideration by Appeals.” An attachment to the notice of determination stated in pertinent part: SUMMARY * * * * * * * The liabilities arose from your failure to file returns for 1995 and 1998. You were sent a Statutory Notice of Deficiency. You had a prior opportunity to appear at an Appeal’s conference and an opportunity to petition the US Tax Court. Therefore, the underlying liability issue is precluded from this determination under Treas. Reg. 301.7122 and IRC §6330. 3Petitioner apparently attached a document to petitioner’s Form 12153 that is not part of the record in this case.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007