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On May 24, 1999, respondent assessed the tax that petitioner
reported in his 1998 return.2 On September 17, 2001, respondent
assessed an addition under section 6651(a)(2) to the unpaid
portion of such tax and interest as provided by law. (We shall
refer to any such unpaid assessed amounts, as well as interest as
provided by law accrued after September 17, 2001, as petitioner’s
unpaid liability for 1998.)
On September 17, 2001, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ity for his taxable year 1998.
On April 8, 2002, 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 his taxable year 1998.
On or about April 28, 2002, in response to the notice of intent
to levy, petitioner filed Form 12153, Request for a Collection
Due Process Hearing (Form 12153), and requested a hearing with
2On Oct. 19, 2001, respondent issued to petitioner a notice
of deficiency (notice) with respect to his taxable year 1998. In
that notice, respondent determined a deficiency of $815 in
petitioner’s tax for that year. Petitioner did not file a
petition with the Court with respect to that notice. On Apr. 29,
2002, respondent assessed the deficiency of $815 that respondent
determined in the notice relating to petitioner’s taxable year
1998. That deficiency is not part of the collection action as
determined in the notice of determination concerning the collec-
tion action for petitioner’s taxable year 1998 upon which this
case is based. Respondent indicates in respondent’s motion that
if respondent proposes to collect the deficiency of $815 that
respondent determined in the notice relating to petitioner’s
taxable year 1998, “Petitioner will be entitled to a separate CDP
hearing” with respect to any such proposed collection action.
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Last modified: May 25, 2011