BobKamman
Level 15

It would have cost $60 to file a Tax Court petition, which is what should have been done as soon as the Notice of Deficiency was issued.  Most Tax Court petitions are "pro per" -- no lawyer represents the taxpayer, but most cases settle before trial.  And nearly every day, the Tax Court reminds  a couple CPAs or EAs  who sign petitions that they shouldn't be doing that -- but it doesn't throw out the case. 

And IRS can't levy without offering a Collection Due Process hearing.  An unfavorable decision there can be appealed to Tax Court, also.  Cost?  $60. 

Asking the local Taxpayer Advocate for help in these cases is like asking the Democratic National Committee for help when you don't like something Joe Biden said.  They're all playing for the same team.  That was the last place to go for help in this situation.  Going to a Member of Congress?  They just send it over to the National Taxpayer Advocate, who might at that point pay more attention to it.  

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