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On March 27, 1998, respondent assessed petitioner’s tax, as
well as additions to tax and interest as provided by law, for
each of his taxable years 1993, 1994, and 1995. (We shall refer
to those assessed amounts, as well as interest as provided by law
accrued after March 27, 1998, as petitioner’s unpaid liability
for each of his taxable years 1993, 1994, and 1995.)
On March 27, 1998, respondent issued to petitioner a notice
of balance due with respect to petitioner’s unpaid liability for
each of his taxable years 1993, 1994, and 1995.
On December 16, 1999, respondent issued to petitioner a
final notice of intent to levy and notice of your right to a
hearing (notice of intent to levy) with respect to (1) peti-
tioner’s unpaid liability for each of his taxable years 1987,
1988, 1989, 1993, 1994, and 1995 and (2) a frivolous return
penalty under section 6702 with respect to each of his taxable
years 1995 and 1996. That notice showed in pertinent part:
2(...continued)
taxpayers with cases in the Court sent to the Internal Revenue
Service in response to the notices issued to them. See, e.g.,
Copeland v. Commissioner, T.C. Memo. 2003-46; Smith v. Commis-
sioner, T.C. Memo. 2003-45.
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