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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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