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This case was submitted to the Court following a trial.
Thereafter, respondent filed a Motion to Permit Levy pursuant to
section 6330(e)(2).
As discussed in detail below, we shall sustain the notice of
determination upon which this case is based. In addition,
respondent has shown good cause for lifting the suspension of the
proposed levy, and we shall grant respondent’s Motion to Permit
Levy, and shall impose a penalty under section 6673.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The parties’ stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Phoenix, Arizona.
On September 27, 2000, respondent issued to petitioner
notices of deficiency for 1993, 1994, 1995, 1996, and 1997.
Petitioner filed with the Court a timely petition for
redetermination at docket No. 13410-00. On April 10, 2002, the
Court entered an Order and Order of Dismissal and Decision at
docket No. 13410-00, denying petitioner’s motion to dismiss,2
dismissing the case on the ground that petitioner failed properly
to prosecute, sustaining the income tax deficiencies and
2 The Court rejected petitioner’s argument that the notices
of deficiency were invalid because they were issued before the
Commissioner complied with the requirements of the partnership
provisions set forth in secs. 6221 to 6234.
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