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On February 26, 2005, respondent’s notice of deficiency was
delivered to and received by petitioner, but petitioner did not
file a petition with this Court to contest respondent’s
deficiency determination.
After assessment of the above deficiency, on October 29,
2005, respondent mailed to petitioner a notice of intent to levy,
and petitioner timely requested of respondent an Appeals Office
collection hearing.
In the Appeals Office hearing, petitioner sought to raise an
issue as to the correctness of respondent’s above tax deficiency
determination, and petitioner requested an abatement of interest
solely on the ground that respondent’s tax deficiency
determination was erroneous. Petitioner did not raise any
collection alternatives, and petitioner did not make or submit to
respondent an offer-in-compromise. Because petitioner had
received respondent’s February 22, 2005, notice of deficiency and
because petitioner could have petitioned the Tax Court with
regard thereto, respondent’s Appeals officer declined to consider
petitioner’s 2002 Federal income tax liability and concluded that
the proposed levy should be sustained. Also, respondent’s
Appeals officer rejected petitioner’s claim for interest
abatement.1
1 Respondent’s motion in limine does not seek to preclude
petitioner from pursuing her claim for interest abatement.
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Last modified: November 10, 2007