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On February 22, 2005, respondent mailed to petitioner a
notice of deficiency reflecting the above $19,923 tax deficiency
and a $3,900 section 6662 accuracy-related penalty.
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.
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Last modified: March 27, 2008