David A. Brown - Page 5

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          miscellaneous payment, combined with a $391.23 overpayment credit           
          relating to the taxpayers’ 1998 taxable year, satisfied the                 
          taxpayers’ liability for the 1995 taxable year.1  On November 23,           
          1999, taxpayers had an overpayment credit balance of $15.63.                
               On November 29, 1999, respondent assessed tax of $25,269, an           
          addition to tax for late filing of $2,207.72, and interest of               
          $2,594.84 relating to the 1996 taxable year.  On December 29,               
          1999, respondent applied $11,425.70 of the tax payments to the              
          taxpayers’ 1996 account.  As reflected on Form 4340 with respect            
          to the taxpayers’ 1996 taxable year, the taxpayers’ account for             
          the 1996 taxable year received the following credits:  $290.14              
          overpayment credit from the 1995 taxable year that the taxpayers            
          elected to apply to 1996; $15.63 overpayment credit balance from            
          the 1995 taxable year as described above; and $455.77 overpayment           
          credit from the 1998 taxable year.  As of January 24, 2003, the             
          taxpayers’ balance due for the 1996 taxable year was $1,736.32.             
               On July 18, 2001, respondent mailed to the taxpayers a Final           
          Notice - Notice of Intent to Levy and Notice of Your Right to a             
          Hearing (final notice) for the 1995 and 1996 taxable years.  The            
          final notice informed the taxpayers of respondent’s intention to            
          levy under section 6331 and of the taxpayers’ right to Appeals              
          Office consideration.  The final notice also included a copy of             


               1  From October 25 to November 23, 1999, an increased                  
          addition to tax and interest accrued in the amount of $7.60.                





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