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THORNTON, Judge: Petitioner seeks review under section
6330(d) of a determination made by respondent’s Office of Appeals
that respondent’s action to collect by levy certain income taxes
for 1989, 1990, 1991, 1992, 1993, 1996, and 1997 may proceed.
Petitioner contests the levy on grounds that respondent is time
barred from collecting taxes for taxable years 1989 and 1990, and
that petitioner has already paid the subject tax liabilities for
the other years in issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code presently in effect, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate herein by this reference. When petitioner filed his
original and amended petitions, he resided in White Lake,
Michigan.
Throughout the years in issue, petitioner was a self-
employed, independent contractor who worked as a carpet installer
for various companies. For each taxable year in issue,
petitioner filed a timely Federal income tax return.1 When he
filed these returns, petitioner remitted no payments for any of
1 For taxable years 1989 and 1990, petitioner filed claiming
head of household status. For taxable years 1991 and 1992,
petitioner filed claiming a status of married filing separately.
For taxable years 1993, 1996, and 1997, petitioner filed claiming
a status of married filing jointly.
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Last modified: May 25, 2011