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Respondent issued Notices of final partnership
administrative adjustments (FPAAs) to DGE 84-4 for at least its
1986 taxable year and to SGE 84-4 for its 1984 through 1986
taxable years.6 After completion of the partnership-level
proceedings, respondent determined deficiencies in petitioner’s
income tax for his 1981 through 1986 tax years.7
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). The final notice included petitioner’s
outstanding tax liabilities for 1981 through 1986, 1988 and 1992.
On March 17, 2002, petitioner submitted a Form 12153,
Request for a Collection Due Process Hearing. Petitioner argued
that the proposed levies were inappropriate and that an offer-in-
compromise should be accepted.
Petitioner’s case was assigned to Settlement Officer Linda
Cochran (Ms. Cochran). Ms. Cochran scheduled a telephone section
6330 hearing for April 13, 2004. On March 25, 2004, petitioner’s
representative, Terri A. Merriam (Ms. Merriam), requested
additional time to submit information to be considered during the
6 The FPAAs and other information specific to DGE 84-4’s
and SGE 84-4’s partnership-level proceedings are not in the
record.
7 It does not appear that the changes made to petitioner’s
income tax for 1988 and 1992 were made pursuant to the orders and
decisions. The details regarding petitioner’s 1988 and 1992
taxable years are not in the record.
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