Luis A. Cortes - Page 3




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          well as interest as provided by law accrued after September 7,              
          1998, as petitioner’s unpaid liability for 1995.)                           
               On February 9, September 7, October 12, and December 28,               
          1998, and April 12, 1999, respondent issued to petitioner sepa-             
          rate notices of balance due with respect to petitioner’s unpaid             
          liability for 1995.                                                         
               On or about April 15, 2000, petitioner filed a tax return              
          for his taxable year 1999 (1999 return).  In his 1999 return,               
          petitioner reported total income of $9,269 and total tax of                 
          $3,872.  When petitioner filed his 1999 return, he did not pay              
          the amount of tax that he owed for that year.                               
               On May 22, 2000, respondent assessed petitioner’s tax, as              
          well as any penalties and interest as provided by law, for his              
          taxable year 1999.  (We shall refer to those assessed amounts, as           
          well as interest as provided by law accrued after May 22, 2000,             
          as petitioner’s unpaid liability for 1999.)                                 
               On May 22, 2000, respondent issued to petitioner a notice of           
          balance due with respect to petitioner’s unpaid liability for               
          1999.  On June 26, 2000, respondent issued a second notice of               
          balance due with respect to such unpaid liability.                          
               On August 31, 2000, respondent issued to petitioner a final            
          notice of intent to levy and notice of your right to a hearing              
          (notice of intent to levy) with respect to his taxable years 1995           
          and 1999.  That notice showed in pertinent part:                            






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