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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 of
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