Eryck C. Aston - Page 5

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          of that business activity to make the memorandum, report, record,           
          or data compilation, shown by the testimony of a qualified                  
          witness, unless the source of information or the method or                  
          circumstances of preparation indicate a lack of trustworthiness,            
          is not excluded by the hearsay rule.  Fed. R. Evid. 803(6); see             
          Clough v. Commissioner, 119 T.C. 183, 188-189 (2002).  The                  
          documents in question are business records prepared by Revenue              
          Agent Bayles.  There is no indication that the method or                    
          circumstances of preparation indicate a lack of trustworthiness.            
          Accordingly, we admit these documents into evidence.                        
          II. Determination To Proceed With Collection                                
               Respondent concedes that the amount he originally assessed             
          for 1992 was in error.  Respondent originally assessed additional           
          taxes due of $303,306 instead of $30,306 (the amount of tax                 
          determined in the notice of deficiency for 1992).  On July 15,              
          2002, respondent abated $273,000 in tax and $174,493.09 in                  
          interest associated with this typographical error.                          
               Section 6320 provides that the Secretary shall furnish the             
          person described in section 6321 with written notice (i.e., the             
          hearing notice) of the filing of a notice of lien under section             
          6323.  Section 6320 further provides that the taxpayer may                  
          request administrative review of the matter (in the form of a               
          hearing) within a prescribed 30-day period.  The hearing                    








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