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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,
1992.
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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