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by levy Federal income taxes owing by petitioner for the year
1990 should proceed. That determination was preceded by
respondent's issuance to petitioner of a notice of intent to levy
and of petitioner's right to a hearing in connection with an
assessed balance of income taxes for 1990 of $486.77 and
statutory additions of $2,142.20.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are made part hereof.
At the time the petition for review was filed, petitioner was a
legal resident of Italy, Texas.
A notice of deficiency was issued to petitioner for 1990,
and respondent's determinations in that notice were never
judicially challenged or litigated by petitioner. Petitioner
was, in due course, assessed for the amounts determined in the
notice of deficiency.2
In his petition for review, petitioner alleges that he had
previously entered into an agreement with a representative of
respondent to the effect that, if he made the equivalent of
monthly payments over a 12-month period totaling $1,296, his
2 The notice of deficiency was not offered into evidence
at trial. It appears that petitioner had not filed a tax return
for 1990; however, after the notice of deficiency was issued,
petitioner filed a return that mirrored the determinations in the
notice of deficiency. In his petition and at the hearing,
petitioner did not allege or contend that he never received the
notice of deficiency.
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