Jose A. Perez - Page 2

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          is whether respondent may proceed with the proposed levy.  We               
          hold that he may.                                                           
               Many of the facts have been stipulated and are so found.               
          The parties’ stipulations of fact and the accompanying exhibits             
          are incorporated herein by this reference.                                  
               At the time the petition was filed, petitioner resided in El           
          Paso, Texas.                                                                
               Petitioner filed his Federal income tax returns for 1984,              
          1985, and 1986 on April 5, 1988, and for 1987 on April 15, 1988.            
          Petitioner did not submit payment of any of the amounts shown as            
          due on the returns, and respondent assessed the amounts shown on            
          each return as due on June 6, 1988, including late filing                   
          penalties and interest.  These assessments will hereinafter be              
          referred to as the “return assessments”.                                    
               On June 6, 1988, respondent sent petitioner notice and                 
          demand for payment with respect to the return assessments.                  
               On April 17, 1989, respondent placed a lien on certain                 
          property of petitioner’s with respect to the return assessments.            
               Upon examination of petitioner’s returns, respondent                   
          concluded that petitioner’s filing status should be changed from            
          head of household to married filing separately, resulting in                
          additional tax liabilities and penalties for 1984, 1985, 1986,              
          and 1987.  Petitioner consented to the immediate assessment of              

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