Gloria M. Stark - Page 4




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               On June 21, 1999, respondent sent petitioner a notice of               
          deficiency for 1995, 1996, and 1997, determining income tax                 
          deficiencies of $7,054, $6,305, and $6,711, respectively, plus              
          additions to tax under sections 6651(a)(1) and 6654 for 1995 and            
          1997.  Petitioner did not petition this Court for                           
          redetermination.                                                            
               On March 29, 1999, respondent assessed the unpaid tax                  
          liability reported on petitioner’s 1994 tax return, plus                    
          penalties and interest.  On February 7, 2000, respondent assessed           
          the income tax deficiencies and additions to tax, plus interest,            
          as determined in the notice of deficiency for 1995, 1996, and               
          1997.                                                                       
               On June 15, 2000, respondent sent petitioner a Final Notice            
          -- Notice of Intent to Levy and Notice of Your Right to a                   
          Hearing, regarding petitioner’s 1994 through 1997 income tax                
          liabilities.  On July 12, 2000, petitioner submitted to                     
          respondent a Form 12153, Request for a Collection Due Process               
          Hearing.  On the Form 12153, the only issue that petitioner                 
          raised was whether payments received from her former husband were           
          taxable to her as alimony.                                                  
               On April 10, 2001, an administrative hearing was held                  
          between petitioner and respondent’s Appeals officer (the                    
          administrative hearing).  On April 30, 2002, respondent issued              
          petitioner a Notice of Determination Concerning Collection                  






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