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3406 and 3509) for the periods ending March 31, 1994, and June
30, 1995. Respondent subsequently determined that petitioner was
liable for a penalty pursuant to section 6672 equal to the unpaid
taxes.1
Respondent subsequently initiated a collection action
against petitioner. On September 2, 1999, respondent's Boston
Appeals Office issued a notice of determination to petitioner
stating in pertinent part:
We have reviewed the proposed collection action for the
periods [May 31, 1994 and June 30, 1995]. This letter
is your legal Notice of Determination, as required by
law. * * *
If you want to dispute this determination in court, you
have 30 days from the date of this letter to file a
complaint in the appropriate United States District
Court for a redetermination.
* * * * * * *
Summary of Determination:
1. It has been determined that all requirements of
administrative procedure and applicable law have been
met with regards to the proposed collection action.
1 Sec. 6672(a) provides in pertinent part:
SEC. 6672(a). General Rule.-–Any person required
to collect, truthfully account for, and pay over any
tax imposed by this title who willfully fails to
collect such tax, or truthfully account for and pay
over such tax, or willfully attempts in any manner to
evade or defeat any such tax or the payment thereof,
shall, in addition to other penalties provided by law,
be liable to a penalty equal to the total amount of the
tax evaded, or not collected, or not accounted for and
paid over. * * *
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