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additional penalty and interest in the total amount of $59,182.
Respondent concedes that we have jurisdiction over respondent’s
proposed tax lien filings relating to petitioner’s unpaid Federal
income taxes for 1984 through 1987 and for 1996.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
The controlling issue before us on respondent’s instant
motion for partial dismissal involves whether respondent mailed
the notice of intent to levy to petitioner at petitioner’s last
known address. This fact issue turns on whether the receipt by
respondent from petitioner -- 32 days before respondent mailed to
petitioner the notice of intent to levy -- of an incomplete tax
return established that petitioner had a new address to which
respondent should have mailed the notice of intent to levy.
FINDINGS OF FACT
On petitioner’s original and amended Federal income tax
returns for 1986 through 1997, as filed with respondent, the
mailing address of petitioner was indicated as 2550 East Desert
Inn Road, Apartment 201, Las Vegas, Nevada 89121 (Desert Inn
address). The Desert Inn address constitutes the address of
Mailbox, Etc., a retail store that provides post office boxes and
other mail services to paying customers, of whom petitioner was
one.
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