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of the years 1994 and 1996 should be reduced from the respective
tax liabilities for those years which respondent had computed and
assessed and to which the notice of intent to levy pertained.
At the February 12, 2001 Appeals Office hearing, the Appeals
Officer attempted to explain to petitioner respondent’s basis for
the tax assessment against him for each of the years 1994 and
1996. The Appeals Officer explained to petitioner that respon-
dent calculated his tax liability for each of the years 1994 and
1996 by preparing a substitute for return for each of those years
on the basis of the information reflected in Form W-2, Wage and
Tax Statement (Form W-2), and Form 1099 that certain payors
issued to petitioner for each of those years. The Appeals
Officer further explained to petitioner that, in preparing each
such substitute for return in order to arrive at petitioner’s tax
liability for each of the years 1994 and 1996, respondent deter-
mined petitioner’s tax bracket and the amount of tax due and
subtracted any credits to which he was entitled.
Petitioner did not want to discuss at the February 12, 2001
Appeals Office hearing the amount of tax that he owed for each of
the years 1994 and 1996 or the proper way in which to prepare
Form 1040 for each of those years. Nor did petitioner wish to
discuss collection alternatives at the February 12, 2001 Appeals
Office hearing.
At the February 12, 2001 Appeals Office hearing, petitioner
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