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Respondent has adduced sufficient documentation showing that
the notice of deficiency for petitioner’s 2002 tax year was
mailed, by certified mail, to her correct address. Petitioner
has not argued or shown that she did not receive or was unaware
of the notice of deficiency. Under the circumstances, petitioner
is statutorily precluded from challenging the merits of her 2002
tax liability in the context of this collection proceeding.3
Respondent’s motion for summary judgment will be granted.
To reflect the foregoing,
An appropriate order and decision
will be entered.
3 The Court inquired about whether respondent and petitioner
were precluded from considering an offer in compromise or some
other remedial approach to resolve petitioner’s underlying 2002
tax liability outside of the sections 6320 and 6330 collection
proceeding. The Court was advised that no such prohibition
existed and that the parties were attempting to resolve this
matter.
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Last modified: March 27, 2008