Shuang-Di Sun Bennett - Page 3

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               Respondent issued to petitioner a Notice of Determination              
          Concerning Collection Action(s) Under Section 6320 and/or 6330              
          (notice of determination), in which respondent sustained a                  
          proposed levy to collect petitioner’s unpaid 1998 tax liability             
          following an administrative hearing.  The issues for decision               
          are:  (1) Whether, in the context of this collection action,                
          petitioner is liable for the underlying tax for the taxable year            
          1998 and, if so, (2) whether respondent may proceed with                    
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts, the supplemental stipulation of           
          facts, and the attached exhibits are incorporated by this                   
          reference.  At the time of filing the petition, petitioner                  
          resided in Monterey Park, California.                                       
               Petitioner is a native of Shanghai, China.  In December                
          1993, petitioner married Alva D. Bennett (Mr. Bennett), a U.S.              
          citizen, and she immigrated to the United States in September               
          1994.  As described by petitioner, Mr. Bennett went to Shanghai             
          to marry her, and then “picked [her] up from the airport” a                 
          little less than a year later.  At some point in 1999, petitioner           
          discovered that Mr. Bennett was having an extramarital affair.              
          Petitioner suspects that the extramarital affair began much                 
          earlier than 1999.  Petitioner continued to reside in the same              

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