- 3 -
On November 17, 1986, respondent assessed the total tax
shown on petitioner’s return, plus additions to tax and interest,
and applied the reported payments. Notices of balance due were
also sent on November 17 and December 22, 1986. Respondent
thereafter examined petitioner’s return and on October 14, 1992,
issued to petitioner a notice of deficiency with respect to 1985.
The notice reflected determinations by respondent of a deficiency
based on unreported income and of additions to tax under sections
6653(b) and 6661.
Petitioner filed a petition with this Court disputing
respondent’s determinations on January 12, 1993, at docket No.
974-93. The case was resolved by entry of a stipulated decision
on December 20, 1995. The decision document provided: “That
there is no deficiency in income tax due from, nor overpayment
due to, the petitioner for the taxable year 1985” and that there
were no additions to tax due from petitioner.
On October 6, 1999, respondent issued to petitioner a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to, among other liabilities, his Federal
income taxes for 1985.3 As of that date, the amount owed by
petitioner for 1985, including additions to tax and interest,
3 The Final Notice--Notice of Intent to Levy and Notice of
Your Right to a Hearing also reflected trust fund recovery
penalties for various quarterly periods in 1982, 1983, and 1986,
which are not at issue in this proceeding.
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