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resided in Philadelphia, Pennsylvania, at the time he filed
the instant petition.
The case is now before the Court to decide respondent’s
motion for summary judgment, filed April 2, 2004, and
petitioner’s motion for summary judgment, filed April 29,
2004.
The pertinent facts, taken from the pleadings and
the motions filed by the parties, are summarized below.
During calendar year 1996, petitioner received wages of
$19,569 and unemployment compensation of $8,500, but he
failed to file an income tax return for the year. As a
result, respondent determined a deficiency of tax and
additions to tax for the year and issued a notice of
deficiency to petitioner setting forth such determination.
Petitioner did not petition this Court for redetermi-
nation of the deficiency and addition to tax. Accordingly,
in due course, respondent assessed a deficiency in
petitioner’s 1996 income tax of $3,602, an addition to tax
under section 6651(a)(1) of $517.95, an addition to tax
under section 6651(a)(2) of $299.26, and an addition to tax
under section 6654(a) of $116.15.
After petitioner failed to pay the amounts assessed,
respondent sent to petitioner Notice of Intent to Levy and
Notice of Your Right to a Hearing, on Internal Revenue
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