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for the period beginning 30 days after March 29, 1994, the date
on which this Court entered the decision in petitioner’s case,
and ending on the dates, respectively, when respondent made
assessments for petitioner’s 1988 and 1990 tax years.4 In
addition to the assessed deficiencies, the addition to tax for
1988, and the penalty for 1990, petitioner’s tax liabilities
included her assessed liabilities for Social Security taxes and
penalties for those two years.
Respondent issued payment notices for petitioner’s 1988 and
1990 assessments on February 13, 1995, July 24, 1995, and March
3, 1997. Additionally, on November 12, 1997, pursuant to a
request by petitioner, respondent issued petitioner a notice with
respect to each year in issue, providing a detailed explanation
of the interest and penalty charged to petitioner’s account.
On August 5, 1995, respondent filed a Notice of Federal Tax
Lien in Camden, New Jersey, with respect to unpaid assessments
due from petitioner for a number of years, including the two
years in issue.
OPINION
Pursuant to section 6404(a), the Commissioner is authorized
to abate the unpaid portion of the assessment of any tax or any
4 We note that the record does not indicate whether
respondent issued a notice or demand for payment upon assessment
for either of the years in issue. However, petitioner has not
alleged that such notice was not received nor does the record so
indicate.
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