Theodore W. Banis, Jr. - Page 3

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               At the time the petition was filed, petitioner resided in              
          Accokeek, Maryland.                                                         
               On May 29, 2001, respondent mailed to petitioner a Final               
          Notice - Notice of Intent to Levy and Notice of Your Right to a             
          Hearing (notice of levy) covering 1994-96.  On June 25, 2001,               
          petitioner timely filed a Form 12153, Request for a Collection              
          Due Process Hearing (request for hearing), for 1994-96.  On July            
          1, 2002, a face-to-face hearing was held involving petitioner and           
          Jacqueline Sansbury, an Internal Revenue Service (IRS) Appeals              
          officer with the IRS Appeals Office in Baltimore, Maryland                  
          (Appeals Officer Sansbury).  On July 25, 2002, respondent mailed            
          to petitioner a Notice of Determination Concerning Collection               
          Action(s) under Section 6320 and/or 6330 (the notice of                     
          determination) sustaining the proposed collection action against            
          petitioner for all years.  Petitioner’s petition and amended                
          petition challenging respondent’s determination were filed August           
          12 and October 15, 2002, respectively.                                      
          Facts Pertaining to 1996                                                    
               On August 11, 1997, petitioner filed his 1996 individual               
          income tax return, Form 1040A, U.S. Individual Income Tax Return,           
          showing total tax due of $12,245, total tax withheld of $2,726,             
          and a balance due of $9,519, which petitioner failed to remit               









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