Cynthia A. Bell - Page 14

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             The undisputed facts are that petitioner filed delinquent                
             returns for 1998 and 1999, and she paid the taxes reported               
             on those returns more than 36 months past the payment due                
             date in the case of the 1998 return, and more than 24                    
             months past the payment due date in the case of the 1999                 
             return.  Respondent assessed the tax shown on each                       
             delinquent return, together with appropriate interest,                   
             and notified petitioner of her outstanding liability.                    
             Petitioner did not pay her outstanding liabilities for 1998              
             and 1999 until approximately two years after she filed her               
             delinquent returns.                                                      
                  Furthermore, it is undisputed that respondent sent to               
             petitioner statutory notices of balance due and a notice of              
             intent to levy with respect to each of the years in issue.               
             The certified transcript of petitioner’s account for 1998                
             shows that respondent issued statutory notices of balance                
             due on July 8 and October 21, 2002, when the balance of                  
             petitioner’s account was $5,038.26 and $1,847.97,                        
             respectively.  These balances are shown on the 1998 status               
             history of petitioner’s account, which is attached to                    
             petitioner’s amended petition.  The certified transcript of              
             petitioner’s account for 1999 shows that respondent issued               
             statutory notices of balance due on June 3 and July 1,                   
             2002, when the balance of petitioner’s account was $884.66               






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