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$8,751, respectively. For 1994, petitioner filed a return
reflecting income from wages resulting in a $17,364 income tax
liability, $10,159 of which was paid by means of income tax
withholding.
Respondent assessed on the unpaid income tax liability
reported by petitioner for 1991 through 1994. Subsequently,
respondent determined, by means of a statutory notice of
deficiency, that petitioner had an income tax deficiency for
1993. In connection with that notice, petitioner did not file a
petition with this Court, and respondent assessed the deficiency.
In March 1999, respondent notified petitioner of the intent to
levy with respect to all 4 taxable years. That notification also
advised petitioner of his right to a hearing.
During April 1999, petitioner submitted a written request
for a Collection Due Process Hearing. The Appeals officer
contacted petitioner by telephone to arrange for a hearing.
Petitioner did not request a face-to-face hearing. Instead,
petitioner advised that he needed additional time to seek an
administrative alternative to collection. The alternative was to
have his employment status changed from employee to self-employed
(independent contractor) for each of the tax years. If
petitioner was successful in that pursuit, he believed that his
tax liability would have either been reduced or eliminated. In
particular, petitioner advised that he wanted time to obtain a
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Last modified: May 25, 2011