Ragnhild Anne Westby - Page 4

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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             

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