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respondent from third-party payors and used in calculating the
determined deficiencies. The Schedules C also contained
deductions claimed by petitioner for various business
expenditures, such as for car and truck expenses, travel, meals
and entertainment, and small tools.
Petitioner did not file a petition with this Court for a
redetermination of the tax liabilities asserted in the statutory
notice. The record in this case does, however, include a copy of
a letter dated September 29, 1994, contained in respondent’s
administrative files and addressed to petitioner at the Newport
Beach location. This letter indicates that it was sent in
response to petitioner’s inquiry regarding the notice of
deficiency dated May 19, 1994, and informs petitioner that the
date for filing a petition with the Tax Court had expired.
Respondent made assessments based on the amounts shown in the
notice, plus statutory interest, on December 5, 1994, and issued
to petitioner a notice of balance due on the same date (as well
as on three subsequent occasions).
On May 26, 1999, respondent issued to petitioner a letter
entitled “FINAL NOTICE--NOTICE OF INTENT TO LEVY AND NOTICE OF
YOUR RIGHT TO A HEARING” with respect to the unpaid tax
liabilities for 1989, 1990, and 1991. Thereafter, on June 25,
1999, respondent received a Form 12153, Request for a Collection
Due Process Hearing, submitted on behalf of petitioner.
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