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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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