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petitioner has not raised any relevant issues relating to the
unpaid tax or the proposed levy, we hold that it was not an abuse
of discretion for respondent to determine to proceed with
collection.
FINDINGS OF FACT
On April 15, 1999, petitioner and his wife filed a joint
Federal income tax return for 1998.1 On the 1998 return,
petitioner reported his total income as zero and his total tax as
zero. On February 22, 2000, respondent issued petitioner a
notice of deficiency for 1998, determining a deficiency of
$4,331. Petitioner did not petition this Court with respect to
the notice of deficiency. On July 9, 2001, respondent assessed
the deficiency, along with additions to tax and interest. On
January 18, 2002, respondent sent petitioner a Final Notice--
Notice of Intent to Levy and Notice of Your Right to a Hearing
Under Section 6330 with respect to petitioner’s income tax
liability for 1998. On February 4, 2002, petitioner submitted a
Form 12153, Request for a Collection Due Process Hearing, to the
Internal Revenue Service Office of Appeals requesting a hearing
under section 63302 (hearing).
1 Although petitioner and his wife filed a joint tax return
for 1998, her liability is not at issue in this proceeding.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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