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states that petitioner received a notice of intent to levy for
1991 when her return showed she was entitled to a refund. On
April 15, 2002, petitioner filed a third supplement, which states
that petitioner had not received responses to repeated phone
calls to respondent regarding the proposed levies. On April 18,
2002, petitioner filed a fourth supplement in which petitioner
objects to the imposition of a penalty and interest on her 1992
tax liability.
On April 1, 2002, respondent filed a response to
petitioner’s motion for litigation and administrative costs.
Respondent’s response states that respondent agrees that
petitioner substantially prevailed but contends that respondent’s
position was substantially justified and that petitioner failed
to exhaust all administrative remedies.
On April 11, 2002, respondent filed a response to
petitioner’s motion to restrain assessment and collection.
Respondent stated that petitioner’s motion was with respect to
1993 and 1994. Respondent informed the Court that the
deficiencies previously assessed for 1993 and 1994 were abated,
that respondent assessed the amounts shown on joint returns of
petitioner and her husband for 1993 and 1994, and that the notice
of intent to levy was with respect to the amount shown on
petitioner’s return, plus penalties and interest. Respondent
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