David M. Priestly, Jr. - Page 5

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               Petitioner describes the examination of his 1988 return as             
          “uncontested”.  He did not petition this Court in response to the           
          above-mentioned notice of deficiency, and the deficiency,                   
          additions to tax, and interest were assessed on November 16,                
               Some time in the middle of 1993, a criminal tax                        
          investigation against petitioner was initiated.  He was charged             
          and convicted of aiding and abetting the filing of false Federal            
          income tax returns.  The criminal activity that resulted in                 
          petitioner’s conviction involved the preparation of fraudulent              
          Schedules C for his clients.  His sentence included a prison                
          term, and he was incarcerated from March 10, 1999, until August             
          1, 2001.  In the course of the criminal investigation,                      
          petitioner’s residence was searched pursuant to a search warrant            
          issued in April 1994.  Some or all of the items seized during the           
          search have not been returned to petitioner.                                
               On January 21, 1999, respondent mailed to petitioner a final           
          notice of intent to levy with respect to his outstanding 1988               
          Federal income tax liability.  On February 22, 1999, respondent             
          received from petitioner a Form 12153, Request for a Collection             
          Due Process Hearing.  The form is signed by petitioner and the              
          Diamond Bar address is shown as petitioner’s address on the form            
          itself, as well as on the envelope in which the form was mailed             
          to respondent.  In the area of the form where the taxpayer is               

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