Michael E. Nestor - Page 4




                                        - 4 -                                         
                                        Additions to Tax                              
          Year      Deficiency     Sec. 6651(a)    Sec. 6654                          
          1990        $2,006         $493.00        $129.46                           
          1991         1,834          455.75         104.73                           
          1992         2,201          550.25          -0-                             
          1993         2,021          493.75          -0-                             
          1994         1,954          254.02          -0-                             
          1995         2,899          202.93          -0-                             
          1996         2,951           29.49         156.93                           
          1997         2,996           89.88          -0-                             
               Petitioner received the notices of deficiency for 1992-97,             
          but he did not file a petition for redetermination of the                   
          deficiencies for 1992-97.                                                   
          B.   The Lien and Levy Proceeding                                           
               On October 21, 1999, respondent issued to petitioner a                 
          Notice of Intent to Levy and Notice of Your Right to a Hearing              
          relating to petitioner’s 1990-97 tax years.  On November 17,                
          1999, petitioner filed a Request for a Collection Due Process               
          Hearing, Form 12153, for tax years 1990-983 in which he                     
          contended:  (1) There was “no valid, underlying assessment” of              
          taxes; (2) he did not receive the “statutory ‘notice and demand’”           
          for payment of the taxes at issue; (3) he did not receive a valid           
          notice of deficiency; and (4) he had no underlying tax liability.           
          In his request for a hearing, petitioner asked that the Appeals             
          officer have at the hearing:  (1) Verification that “the                    



               3  The record is silent as to why petitioner requested a               
          hearing with respect to tax year 1998.  Because respondent’s                
          notice of intent to levy did not include 1998, that year is not             
          in issue here.                                                              





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