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FINDINGS OF FACT
Most facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the accompanying
exhibits. We find the stipulated facts accordingly. Petitioner
resided in Florida when his petition was filed.
On September 26, 1998, respondent mailed to petitioner
notices of deficiency in his 1995 and 1996 Federal income taxes.
Petitioner never petitioned the Court with respect to either
notice. On June 9, 1999, respondent’s examination office in
Holly Hill, Florida (Holly Hill), issued to petitioner for those
years and 1997 a document that read in relevant part as follows:
FINAL NOTICE
NOTICE OF INTENT TO LEVY AND NOTICE OF YOUR RIGHT TO A HEARING
PLEASE RESPOND IMMEDIATELY
Your Federal tax is still not paid. We previously
asked you to pay this, but we still haven’t received
your payment. This letter is your notice of our intent
to levy under Internal Revenue Code (IRC) Section 6331
and your right to receive Appeals consideration under
IRC Section 6330.
* * * * * * *
If you don’t pay the amount you owe, make
alternative arrangements to pay, or request Appeals
consideration within 30 days from the date of this
letter, we may take your property, or rights to
property, such as real estate, automobiles, business
assets, bank accounts, wages, commissions, and other
income. We’ve enclosed Publication 594 with more
information, Publication 1660 explaining your right to
appeal, and Form 12153 to request a Collection Due
Process Hearing with Appeals. * * *
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Last modified: May 25, 2011