-5-
decision of the Tax Court has become final.” That stipulated
decision was entered by the Court on February 27, 1997.
On May 5, 1997, on the basis of the stipulated decision,
respondent assessed the 1990, 1991, and 1992 Federal income tax
liabilities of petitioner and Ms. Craig.
B. Income Tax Return for 1995
On December 4, 1997, petitioner filed a 1995 Federal income
tax return. On the basis of this return, respondent assessed
petitioner’s tax liability for 1995 on January 12, 1998.
C. Request for a Hearing
On February 22, 2001, respondent mailed to petitioner and
Ms. Craig a letter, “Final Notice - Notice of Intent to Levy and
Notice of Your Right to a Hearing” (final notice), for 1990,
1991, and 1992. On the same day, respondent mailed to petitioner
a final notice for 1995. Both final notices were signed by a
chief of the IRS Automated Collection Branch in Ogden, Utah.
These notices informed petitioner and Ms. Craig of (1)
respondent’s intent to levy upon their property pursuant to
section 6331 and (2) their right under section 6330 to a Hearing
with respondent’s Office of Appeals (Appeals). Enclosed with the
final notices were copies of Forms 12153, Request for a
Collection Due Process Hearing. On March 17, 2001, petitioner
requested timely the referenced Hearing for 1990, 1991, 1992, and
1995 by mailing to respondent a letter accompanied by two Forms
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