Sandra L. Andary-Stern - Page 7




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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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