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deficiency, petitioner requested a section 6330 hearing with
respondent’s Appeals Office.
Respondent’s Appeals Office denied petitioner’s request as
untimely, but petitioner and respondent’s Appeals Office
nevertheless conducted what respondent treated as an equivalent
hearing wherein petitioner and respondent’s Appeals officer
discussed the issue as to the taxability of discharge of
indebtedness income relating to the 1996 foreclosure sale of
petitioner’s home and petitioner’s 1996 Federal income tax
liability. At this hearing, respondent’s Appeals Office invited
petitioner to file her own 1996 individual Federal income tax
return.
On December 23, 2003, respondent mailed to petitioner’s
current address an adverse decision letter relating to the above
hearing. In the letter, the Appeals Office sustained
respondent’s proposed levy and explained that petitioner had been
given an opportunity during the equivalent hearing, and had been
requested, to submit to respondent’s Audit Reconsideration
Program an individual Federal income tax return for 1996 (as well
as other overdue individual Federal income tax returns that
petitioner had not yet filed).
Petitioner did not file an action in this Court or in a
District Court with regard to respondent’s December 23, 2003,
adverse decision letter, in which petitioner might have argued
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Last modified: November 10, 2007