- 3 - 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.Page: Previous 1 2 3 4 5 NextLast modified: March 27, 2008