- 2 - is whether respondent may proceed with the proposed levy. We hold that he may. Background 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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