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of petitioner’s hearing request as an equivalent hearing. With
regard to the notice of intent to levy, respondent’s Appeals
officer treated the hearing as a section 6330 collection hearing.
On July 6, 2006, respondent’s Appeals Office mailed to
petitioner an adverse decision letter relating to the notice of
tax lien filing and an adverse notice of determination relating
to the notice of intent to levy.
During the above Appeals Office collection hearing
petitioner raised a number of issues, primarily a challenge to
the underlying tax deficiencies that had been redetermined by
this Court. Petitioner complained about the statutory interest
that had accrued during the long period of time from the filing
in August 1992 of petitioner’s 1988 and 1989 Federal income tax
returns to the entry in 2004 of the above Tax Court decision, and
petitioner made a vague claim to her entitlement to a credit for
payments made by her former husband on his Federal income taxes
for 1988 and 1989.
In her petition herein, petitioner challenges only the
correctness of the underlying Federal income tax deficiencies
redetermined by this Court relating to petitioner’s Federal
income tax liabilities for 1988 and 1989. In her petition,
petitioner made no claim for interest abatement.
Petitioner’s petition states only as follows with regard to
the basis for her objection to respondent’s proposed collection
activity:
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Last modified: November 10, 2007