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and 1994 Federal income tax liabilities. The issue for our
consideration is whether respondent abused his discretion by
determining to proceed with the proposed levy.
FINDINGS OF FACT2
At the time of the filing of the petition in this case,
petitioner resided in Rockville, Maryland. On April 11, 2001,
petitioner was provided with the opportunity to contest his 1992,
1993, and 1994 income tax deficiencies in a trial before this
Court. On December 12, 2001, the Court held in a Summary
Opinion, inter alia, that petitioner was engaged in a money-
lending business for the years 1992 to 1994 and was allowed to
deduct certain expenses associated with that business. See
Hajiyani v. Commissioner, T.C. Summary Opinion 2001-183.
In the above-referenced deficiency proceeding, the parties
were required to provide the Court with computations reflecting
the holdings in T.C. Summary Opinion 2001-183 for purposes of
entry of decision. See Rule 155. Respondent submitted a
computation, but petitioner did not. After a time, respondent
moved for an entry of decision in accord with his proposed
computation, which was based on the Court’s Summary Opinion.
On February 22, 2002, petitioner, through his attorney,
Kenneth Wall, filed an objection to the entry of decision,
2The parties’ stipulation of facts is incorporated by this
reference.
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