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but did not petition this Court with respect to the notice of
deficiency. Subsequently, respondent assessed the income tax
deficiency, additions to tax, and interest against petitioner on
August 19, 1997.
On December 17, 2001, respondent mailed to petitioner a
Final Notice - Notice of Intent to Levy and Notice of Your Right
to a Hearing (Letter 1058) covering the taxable years 1993 and
1994 after identifying a potential levy source. On December 29,
2001, petitioner timely submitted Form 12153, Request for a
Collection Due Process Hearing, to respondent requesting a
hearing under section 6330. On Form 12153, petitioner identified
the taxable periods at issue as “beginning Jan. 1, 1993, ending
Dec. 31, 2001” and supplied the following reasons for contesting
the proposed collection action:
Claimant never received cash. Claimant received bills
of credit. Claimant provides noteable service.
Claimant unable to meet cash demands. Claimant DNA is
75+ years. Claimant did not file 1993 and 1994 1040A.
Civil penalties don’t apply. See 1040 & Sched. R.
Attached to the Form 12153 was a Form 1040, U.S. Individual
Income Tax Return, for the period “Jan. 1, 1993, ending Dec. 31,
2001” containing handwritten entries claiming no gross income, no
taxable income, no tax payments, and no tax due. On the Form
1040, petitioner wrote on line 61 (used for entering the amount
of tax overpaid), the word “UNKNOWN” and wrote “MAXIMUM” on line
62 (used to quantify the tax refund due).
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