Linh N. Nguyen - Page 3

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               This case is before the Court on respondent's motion for               
          summary judgment under Rule 121.  This proceeding arises from a             
          petition for judicial review filed in response to a Notice of               
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 sent to petitioner.                                             
                                     Background                                       
               Respondent issued to petitioner a notice of deficiency for             
          taxable years 1994 and 1995.  The notice determined deficiencies            
          of $12,510 and $10,626 for 1994 and 1995, respectively.  The                
          notice also determined an addition to tax under section                     
          6651(a)(1) for failure to timely file an income tax return for              
          1994 of $2,720.  In addition, respondent issued to petitioner a             
          notice of deficiency for taxable year 1996 determining a                    
          deficiency of $3,878 and an accuracy-related penalty under                  
          section 6662(a) of $776.                                                    
               Both notices were sent to petitioner and his wife, Lan Thi             
          Nguyen,1 at 316 Pennsylvania Avenue, Downingtown, Pennsylvania              
          19335-2645.  Neither petitioner nor his wife filed a petition               
          with the Tax Court in response to the notices of deficiency.                
          Subsequently, respondent assessed the deficiencies and interest             
          for tax years 1994 and 1995.  Respondent also assessed the                  



               1Mrs. Nguyen did not sign the Form 12153, Request for a                
          Collection Due Process Hearing, or participate in the collection            
          due process hearing and is not a party to this case.                        




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