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of deficiency. On May 23, 1997, respondent sent petitioner a
second notice, which corrected a typographical error in the April
18, 1997, notice. Petitioner did not file a petition with the
Court to challenge either notice. On October 13, 1997,
respondent assessed a $42,859 deficiency and, pursuant to
sections 66511 and 6654, a $4,027.50 addition to tax and a
$676.92 addition to tax, respectively.
On December 31, 1997, respondent sent a Form 668-W(c),
Notice of Levy on Wages, Salary, and Other Income (notice of
levy), to petitioner’s employer, United Airlines (United). The
notice of levy required United to relinquish a portion of
petitioner’s pay to satisfy his 1994 tax liability.
Respondent, on February 16, 2001, sent petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing, relating to his 1994 tax liability. On March 14, 2001,
petitioner sent respondent Form 12153, Request for a Collection
Due Process Hearing, in which petitioner alleged that the tax
liability had been fully paid. On August 10, 2001, the Appeals
officer held a conference with petitioner. The Appeals officer
reviewed transcripts of petitioner’s 1994 income tax account and
payroll records. The payroll records indicated that between
October 20, 1997, and November 17, 1998, United, pursuant to an
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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Last modified: May 25, 2011