Jerome Griggs Beery - Page 2




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          against him.  The case originated with respondent's issuance to             
          petitioner of two final notices of intent to levy.  One notice              
          dealt with petitioner's 1989, 1990, and 1991 tax years, and the             
          other notice dealt with petitioner's 1994 tax year.  In both                
          instances, petitioner responded timely with a Request for a                 
          Collection Due Process Hearing.  A hearing was held with                    
          petitioner by telephone with respect to both requests.                      
          Thereafter, respondent issued separate notices of determination             
          advising petitioner that respondent would proceed with                      
          collection.  This petition for review followed.                             
               The Federal income taxes and penalties at issue are based on           
          two notices of deficiency issued to petitioner and his spouse,              
          Joyce E. Beery, as follows:2                                                

          Year       Deficiency       Sec. 6662(a) Penalty                            
          1989         $28,242              $5,648                                    
          1990          24,401               4,880                                    
          1991           4,624                 --                                     
          1994          21,592               4,318                                    





               2    The collection activity was instituted only against               
          petitioner and not his spouse.  One notice of deficiency was for            
          the years 1989, 1990, and 1991, and the other notice of                     
          deficiency was for the years 1992, 1993, and 1994.  The                     
          collection activity at issue is not directed to petitioner's 1992           
          and 1993 tax liabilities.  The record is unclear as to the amount           
          owing for the 1989, 1990, and 1991 tax years; however, for the              
          year 1994, the final notice of intent to levy to petitioner                 
          stated a total of taxes, penalties, and interest of $34,447.88.             




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