Daniel and Sally A. Holguin - Page 6

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          liabilities for 1995 and 1996.)                                             
               On August 17, 1998, respondent issued to Mr. Holguin a                 
          notice of balance due with respect to Mr. Holguin’s unpaid                  
          liabilities for 1995 and 1996.                                              
               On August 31, 1998, respondent assessed Mr. Holguin’s tax,             
          as well as an addition to tax and interest as provided by law,              
          for his taxable year 1994.  (We shall refer to those assessed               
          amounts, as well as interest as provided by law accrued after               
          August 31, 1998, as Mr. Holguin’s unpaid liability for 1994.)               
               On August 31, 1998, respondent issued to Mr. Holguin a                 
          notice of balance due with respect to Mr. Holguin’s unpaid                  
          liability for 1994.                                                         
               On February 5, 1999, respondent issued to petitioner Sally             
          A. Holguin (Ms. Holguin) a final notice of intent to levy and               
          notice of your right to a hearing (notice of intent to levy) with           
          respect to Ms. Holguin’s taxable years 1994, 1995, and 1996.  (We           
          shall refer to the notice of intent to levy issued to Ms. Holguin           
          as respondent’s February 5, 1999 notice of intent to levy con-              
          cerning Ms. Holguin’s taxable years 1994, 1995, and 1996.)                  
               On October 4, 2001, respondent issued to Mr. Holguin a                 
          notice of intent to levy with respect to Mr. Holguin’s taxable              
          years 1994, 1995, and 1996.  (We shall refer to the notice of               
          intent to levy issued to Mr. Holguin as respondent’s October 4,             
          2001 notice of intent to levy concerning Mr. Holguin’s taxable              






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