- 4 - 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 arguedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007