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respondent’s Collection Division be allowed to proceed with
appropriate action to collect from petitioner certain income
taxes for 1991 and 1992. Petitioner asks us to review such
determination.
Unless otherwise indicated, all section references are to
the Internal Revenue Code presently in effect.
FINDINGS OF FACT
At the time the petition was filed, petitioner resided in
Provo, Utah.
On September 28, 1994, respondent mailed a notice of
deficiency (the notice of deficiency) to petitioner, determining
deficiencies in, and additions to, his Federal income taxes for
petitioner’s taxable (calendar) years 1991 and 1992. On
October 18, 1994, petitioner received the notice of deficiency
and signed the domestic return receipt, Postal Service Form 3811,
which accompanied the notice of deficiency.
On March 13, 1995, respondent assessed taxes, an estimated
tax penalty, and late filing penalty in the amounts of $10,138,
$581, and $2,535, respectively, for 1991. Also, on March 13,
1995, respondent assessed taxes, an estimated tax penalty, and
late filing penalty in the amounts of $10,394, $453, and $2,599,
respectively, for 1992.
On June 15, 1999, respondent mailed a final notice of intent
to levy to petitioner. That notice states that petitioner owed
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