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shall grant respondent’s motion, as supplemented.
Background
On January 20, 1996, respondent served the City of
Philadelphia with a Notice of Levy on Wages, Salary, and Other
Income in an effort to collect taxes due from Janice Bullock
(petitioner) for 1991 and 1992. On May 15, 1996, respondent
served Corestates Bank with a Notice of Levy in a further effort
to collect taxes due from petitioner for 1991 and 1992. On April
3, 1997, respondent issued to petitioner a Final Notice–-Notice
of Intent to Levy regarding her unpaid taxes for 1991 and 1992.
On April 24, 2000, respondent issued to petitioner a notice that
respondent had applied $1,027.79 of taxes that she overpaid on
her Federal income tax return for 1999 to taxes remaining due for
the taxable years 1992 and 1993.
On November 29, 2000, respondent issued to petitioner a
Final Notice–-Notice of Intent to Levy and Notice of Your Right
to a Hearing with regard to her unpaid taxes for the taxable
years 1993, 1994, 1995, and 1996. On December 26, 2000,
petitioner filed with respondent a Form 12153, Request for a
Collection Due Process Hearing. Petitioner subsequently attended
an administrative hearing at respondent’s Appeals Office in
Philadelphia, Pennsylvania.
On February 19, 2002, respondent sent to petitioner by
certified mail a Notice Of Determination Concerning Collection
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