Paul F. Nichols and Eleanore M. Nichols - Page 2




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          the levy to collect 1996 Federal income taxes of approximately              
          $135,024.03.1                                                               
               We sustain respondent’s filing of the notice of lien and               
          respondent’s determination as to the proposed levy.  Unless                 
          otherwise noted, section references are to the applicable                   
          versions of the Internal Revenue Code.  Rule references are to              
          the Tax Court Rules of Practice and Procedure.                              
                                     Background                                       
               Petitioners filed a joint 1996 Federal income tax return on            
          October 20, 1997.  Respondent assessed the Federal income tax               
          liability shown on that return on November 24, 1997.                        
               On July 25, 2000, respondent sent to petitioners a notice of           
          deficiency for 1996.  The notice of deficiency determined that              
          petitioners were liable for a deficiency of $83,521 and an                  
          accuracy-related penalty of $16,704.20 under section 6662(a).               
          Petitioners did not petition this Court with respect to the                 
          notice of deficiency.  On December 18, 2000, respondent assessed            
          the amount of the deficiency and accuracy-related penalty shown             
          in the notice of deficiency.                                                
               On April 12, 2001, respondent mailed to each petitioner an             
          identical letter, Final Notice - Notice of Intent to Levy and               
          Notice of Your Right to a Hearing (final levy notice).  The final           


               1 We use the term “approximately” because these amounts were           
          computed before the present proceeding and have since increased             
          on account of interest.                                                     




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