Jeffrey K. Ramsdell - Page 3

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               Respondent assessed petitioner’s tax liabilities for 1992               
          and 1993 on November 26 and October 1, 2001, respectively; the               
          assessments amounted to $15,779 for 1992 and $6,092 for 1993.                
               On April 15, 2002, respondent sent petitioner Notices of                
          Intent to Levy for 1992 and 1993.  On May 30, 2002, petitioner               
          sent respondent Form 12153, Request for a Collection Due Process             
          Hearing, in which he contested the collection proceedings with               
          respect to the years at issue and requested a section 6330                   
          hearing (hearing).  In his statement of reasons for disputing                
          respondent’s actions, petitioner asserted that his liabilities               
          were discharged in the bankruptcy proceedings, and that “[t]he               
          Service has for over 2 years constructive notice of my                       
          situation.”  On November 12, 2002, respondent held a telephonic              
          hearing with petitioner.                                                     
               On January 17, 2003, respondent sent petitioner a Notice of             
          Determination, stating there was no record that petitioner’s                 
          liabilities were discharged in bankruptcy and indicating                     
          respondent’s intent to proceed with the levy with respect to the             
          years at issue.5                                                             
               Petitioner filed his amended petition contesting the Notice             
          of Determination with this Court on February 26, 2003.  In the               


               5 The Notice of Determination stated, in the section                    
          captioned “Issues Raised by the Taxpayer” that “[y]ou contend                
          that the liabilities at issue were discharged in bankruptcy, but             
          there is no record of that.”                                                 





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