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issue for decision is whether respondent may proceed with the
proposed levy. We hold that he may.
Background
Petitioner was a resident of American Canyon, California,
when his petition was filed.
Petitioner timely filed a 1992 individual Federal income tax
return reporting tax due of $716. After correcting the return
for computational and clerical errors, respondent assessed the
tax due thereon of $1,061 on June 7, 1993.
Petitioner did not timely file a Federal income tax return
for 1993 or 1995. On October 6, 1997, respondent prepared a
substitute for return for each year, and on May 18, 1998,
respondent assessed tax of $2,903 for 1993 and $6,138 for 1995.2
Petitioner filed 1993 and 1995 individual Federal income tax
returns on September 21 and 18, 1998, respectively. Respondent
subsequently abated the assessment for each year to reflect the
tax reported on petitioner's returns after correcting for
computational and clerical errors.
Petitioner filed a 1994 individual Federal income tax return
on September 21, 1998; an assessment of $2,974 was made with
respect to that return.
2 Respondent concedes that notices of deficiency for these
years were not received by petitioner.
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