Doris Lee Newsome - Page 4




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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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