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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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